Deposition Preparation

Master Prompt for AI-Powered Deposition Preparation

Instructions for Use: Execute the following prompts sequentially. Each prompt builds upon the output of the previous one to create a complete and strategic deposition preparation file.

Prompt 1: Foundational Case Blueprint

"Assume the role of a senior litigation paralegal. Your task is to create a foundational 'Case Blueprint' from the entire set of case files provided.

First, analyze all documents in the 'Pledings and Motions' folder. Extract and list every cause of action from the complaint(s) and every affirmative defense from the answer(s). For each, provide a concise summary of the key factual allegations or denials.

Second, for each cause of action and affirmative defense, research and list the essential legal elements required for proof under the governing law of.

Third, scan the entire case file and generate a 'Key Players' list of all individuals and entities. For each, provide a brief summary of their role, title/position, and their relationship to other key players.

Finally, synthesize this information to propose one primary and two alternative case theories for our side. For each theory, list the key facts that currently support it and identify the primary evidentiary gaps that subsequent analysis should seek to address.

Present the final output as a single, well-organized document titled 'Case Blueprint'."

Prompt 2: Comprehensive Deponent Profile

"Using the entire case file and focusing on the deponent,, generate a 'Witness Dossier.'

First, search the entire case file for every mention of the deponent. Extract each mention along with the surrounding paragraph for context and cite the source document's Bates number.

Second, identify and collate all prior statements made by the deponent from all sources (emails, memos, reports, discovery responses). Analyze these statements for internal consistency and cross-reference them against the statements of other parties to identify and list all potential contradictions.

Third, identify every document the deponent authored, received, was copied on, or was mentioned in. Based on this, generate a communication network map showing who the deponent communicates with most frequently and the primary topics of those communications.

Finally, synthesize all of the above into a 'Witness Vulnerability Report' that identifies: 1) Key inconsistencies in their statements. 2) Apparent gaps in their knowledge where they should have been informed. 3) Potential biases based on their relationships. 4) A linguistic profile based on their authored documents, noting their typical communication style (e.g., formal, informal, technical, evasive). 5) Any key events where their documented actions or communications deviate from this baseline profile."

Prompt 3: Master Chronology and Evidence Synthesis

"Your task is to transform the case documents into a unified narrative and a curated evidence set.

First, scan every document in the entire case file. Generate a 'Master Chronology' of every date-stampable event, communication, or action. Each entry must include the date and time (if available), a brief, neutral description of the event, and the Bates numbers of all source documents that evidence the event.

Second, analyze the generated Master Chronology to identify and report on: 1) Significant temporal gaps where key actions are expected but not documented. 2) Illogical sequences of events. 3) Instances where different documents present conflicting information about the same event.

Third, generate a 'Key Deponent Document Dossier' for in a table format. The table should include only the most critical documents and contain the following columns: 'Exhibit No.', 'Bates No.', 'Date', 'Document Type', 'Author/Sender -> Recipient(s)', 'AI-Generated Relevance Summary', 'Key Themes', and 'Contradictions/Flags'."

Prompt 4: Dynamic Questioning Modules

"Using the 'Case Blueprint,' 'Witness Dossier,' and 'Master Chronology' previously created, your task is to architect a comprehensive set of 'Dynamic Questioning Modules' for the deposition of. Do not create a simple linear list of questions.

First, generate distinct questioning modules organized by: 1) Each key legal element identified in the Case Blueprint. 2) Each major disputed factual issue. 3) Critical time periods identified in the Master Chronology.

Second, for each document listed in the 'Key Deponent Document Dossier,' generate a specific question set that includes foundational questions for authentication and substantive questions probing the document's content and the deponent's actions related to it.

Third, using the 'Witness Vulnerability Report,' generate specific 'Contradiction Confrontation Scripts.' Each script must be a question sequence that: 1) Commits the witness to one version of the facts. 2) Introduces the conflicting evidence. 3) Asks the witness to explain the discrepancy."

Prompt 5: Final Strategy Memo and Iterative Review

"Your final task is to synthesize all previous outputs into a 'Final Deposition Strategy Memo.'

Review the initial case theories from the 'Case Blueprint' in light of the 'Witness Vulnerability Report' and the 'Dynamic Questioning Modules.' Propose revisions to the case theories to better align with the evidence you have analyzed.

Based on this refined strategy, generate a final, prioritized list of the top 5-7 objectives for this deposition. For each objective, specify which questioning modules are designed to achieve it.

Conclude by identifying any remaining factual gaps or weaknesses that this deposition must fill as a top priority."