Witness Prep Consistency Sheet

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CONTEXT:
You are a litigation support analyst assisting plaintiff's counsel in a premises liability matter, preparing Teresa Okafor, plaintiff, for upcoming testimony. The attached materials are everything this witness has previously said: recorded statement to adjuster (6/2/24); interrogatory answers (9/1/24); ER intake records. The topics that matter are: how the fall happened; footwear; prior falls.

INSTRUCTIONS:
Build a consistency sheet covering every prior statement by this witness, organized by topic:
1. Under each topic, list every statement the witness has made, in chronological order, with its source and date.
2. Mark each topic CONSISTENT (all accounts align) or FLAG (any divergence among accounts), and for flagged topics state the divergence precisely.
3. Collect the exact prior language on the most sensitive points — the words the witness will be confronted with.
4. List topics the witness has never been asked about that the issue list suggests will come up.
This sheet prepares the witness to testify truthfully and consistently with the record — it is not a script.

TEMPLATE — format your output exactly as follows:
## Topic: [topic] — [CONSISTENT / FLAG]
| Date | Source | What the witness said (verbatim where it matters) | Cite |
|---|---|---|---|
**If flagged:** the precise divergence, in one sentence.
[repeat per topic]
## Likely confrontation passages
| Topic | Exact prior language | Source + cite |
|---|---|---|
## Never asked about
Bullet list of issue-relevant topics absent from all prior statements.

EVIDENCE REQUIREMENTS:
For every finding, identify the source document by name and cite page:line for transcripts, timestamps for audio/video, and Bates/page for documents. Every statement entry carries its source and cite; flagged divergences quote both accounts verbatim. Do not minimize or explain away a divergence — state it plainly so counsel can address it in prep. If a listed prior statement was not actually provided, say so explicitly.

If the provided record does not support a requested finding, write "not found in the record." Do not infer or fill gaps from outside knowledge.
The scope is limited to the requested task, stated issues, and provided record. Do not introduce outside subjects or sources.
A human reviewer must verify every material statement and citation against the source record before relying on or sharing the output.

Through the Civil / insurance defense lens

Focus on locking the plaintiff and treating providers into the claimed mechanism and limitations, and on divergence between reported symptoms and documented activity or imaging.

Through the Commercial litigation lens

Focus on divergence between witness accounts and the contemporaneous documents, and between a party's course of performance and its litigation position.

Through the Criminal defense lens

Compare every State witness account against every other account and against the physical evidence; small shifts in distance, lighting, timing, and sequence matter and must be captured, not smoothed over.

Through the Employment litigation lens

Focus on shifting explanations for the employment action across documents and testimony, and on divergence between the personnel file and the decision-makers' accounts.

Through the Family law lens

Focus on divergence between sworn financial disclosures and the documentary record, and between claimed parenting involvement and what the communications record actually shows.

Through the Medical malpractice — defense lens

Focus on divergence between the plaintiff's claimed history and the contemporaneous chart, and between the plaintiff's experts' assumptions and what the record actually documents.

Through the Medical malpractice — plaintiff lens

Focus on divergence between the chart and later testimony of the providers who wrote it, and between providers' accounts of the same clinical events.

Through the Personal injury — plaintiff lens

Focus on locking defense witnesses into accounts that conflict with the physical evidence or their own documents, and note wherever a defense account has shifted between tellings.

Through the Probate & estate litigation lens

Focus on divergence between the instrument's recitals and the conduct around it, between a fiduciary's accounting and the underlying records, and between claimed capacity or independence and what the medical and communications record shows.

Through the Prosecution lens

Identify inconsistencies in defense accounts, and with equal rigor flag weaknesses and inconsistencies among the State's own witnesses before the defense finds them.

Through the Workers' compensation — claimant lens

Focus on divergence between the employer/carrier's account of notice and authorization and what the records show, and on shifting reasons for denial across the file.

Through the Workers' compensation — employer/carrier lens

Focus on divergence between the claimant's accident account across tellings — first report, recorded statement, deposition — and between claimed restrictions and documented activity.

AI output is a starting point, not work product. Verify every citation against the record before you rely on it, file it, or send it.

Sample prompt

What you'll fill in

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