Prompt
You are a litigation support assistant helping an attorney prepare a deposition outline. Work ONLY from the information I provide — do not invent facts, documents, or testimony. Where a line of questioning depends on a document or fact I have not given you, insert [NEED DOC: description] instead of assuming it exists.

Case background: {{case_summary}}
Witness and their role: {{witness_role}}
Key documents and known facts (my summaries): {{key_documents}}
What I need from this deposition: {{deposition_goals}}

Produce a working outline:
1. Foundation module: background, role, and knowledge-establishing questions.
2. Topic modules in logical order. For each: the goal in one line; open-ended questions moving from broad to specific, one fact per question, no compound questions; the document to introduce with an [Ex. __] placeholder; follow-up branches for the two most likely answers.
3. Admissions to lock in, phrased as short leading questions for the end of each module.
4. A closing checklist: exhibits to authenticate, privilege landmines to avoid, and open [NEED DOC] items.

No legal conclusions or objections coaching — this is a draft outline for attorney revision.

Fill in your details and the prompt updates live — then copy.

What you get back (excerpt)

Module 3 — Afternoon inspections (Goal: establish no inspection occurred after 2:00 pm) - Walk me through how aisle inspections were supposed to work on a normal shift. - Who was responsible for inspections that afternoon? - [Introduce Ex. 7 — sweep log] What do the entries between 2:00 and 4:00 pm show? - If witness claims inspections happened but weren't logged: Where would that be documented? [NEED DOC: any policy allowing unlogged inspections] Admissions to lock in: the sweep log contains no entries between 2:00 and 4:00 pm; the witness cannot identify any record of an inspection during that window.

The full workflow

  1. Write your own one-paragraph case summary and bullet the key documents — this forces the anonymization step.
  2. Run the prompt and reorganize the modules into your preferred examination order.
  3. Check every question against the actual exhibits and fill each [NEED DOC] gap.
  4. Add jurisdiction-specific ground rules (time limits, objection practice, your judge's standing orders).
  5. Print with exhibit tabs keyed to the [Ex. __] placeholders.

Watch out for

Your deposition strategy is attorney work product — pasting it into a consumer tool that retains or trains on inputs risks both privilege arguments and confidentiality violations. Anonymize the file summary or use a firm-approved zero-retention tool.

The outline is only as good as your summaries; AI will happily build a confident module around a document mischaracterization, so verify each question against the real exhibit before you rely on it.

AI doesn't know your judge's deposition conduct rules or protective orders in the case — layer those in yourself.

Where this comes from

Every use case on this site is grounded in real reports from working lawyers — not invented by us.

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