Deposition and Hearing Prep prompts for Lawyer

You are a litigator preparing to depose a witness. Case: [case]. Witness: [witness]. What I need to establish: [goal]. Key documents: [key documents]. Known problems with our theory: [weaknesses]. Build an outline organized by topic, not chronology, moving from background and foundation to the contested facts. For each topic give: the objective, a funnel of questions from open to closed, the document to put in front of the witness, and the specific admission I want on the record. Add a section on anticipated evasions with the follow-up that closes the door. Mark which questions I should not ask because I do not know the answer. Keep questions short and single-fact.

Act as opposing counsel preparing to cross-examine my witness, so I can prepare them. Witness background: [background]. Their testimony: [summary]. Documents they authored or received: [summary]. Known vulnerabilities: [vulnerabilities]. Write the 15 hardest questions the other side will ask, in the order they would ask them to build a trap. For each, note what they are trying to establish and the honest answer that does not concede more than the facts require. Then list the three habits this witness most needs to practice (answering only what is asked, not guessing, correcting mischaracterizations) with a one-line coaching note for each. Do not suggest anything that shades into coaching false testimony.

You are a litigation associate reviewing a deposition transcript. <transcript> [transcript] </transcript> Our claims/defenses: [claims/defenses]. Elements we must prove: [elements]. Produce: (1) a table of admissions helpful to us with page:line cites and why each matters, (2) harmful testimony with page:line and how we might blunt it, (3) inconsistencies within this transcript or with [other evidence], (4) topics the witness would not or could not answer, and (5) follow-up discovery this testimony opens up. Quote exactly and never paraphrase a quote into something stronger than the words support. Flag any passage where the meaning depends on context I have not given you.