Prepare a Personal Injury Client for Deposition: Prep Plan and Plain-Language Client Guide
Builds an internal deposition preparation plan from the record you paste (topic map, record-based risk areas, prior history, social media and surveillance exposure) and a plain-language guide for the client that coaches process, never answers.
The Prompt
Variables (6)
| Variable | Description | Example |
|---|---|---|
| {{client_name}} | Client Name | Daniel Brooks |
| {{deposition_date}} | Deposition Date | 2026-11-18 |
| {{court_and_governing_rules}} | Court and Governing Rules | Superior Court of Maricopa County, Arizona. Rule text on depositions pasted below; protective order dated 07/14/2026 pasted below. |
| {{attorney_instructions}} | Attorney Instructions for Client Guide | Tone: calm, short sentences. Tell the client to bring photo ID. Do not mention the 2019 knee injury in the guide. |
| {{case_summary_and_records}} | Case Summary and Records | Incident 03/12/2026, rear-end collision. ER 03/12; PT 04/02 to 07/16 (16 weeks); L4-L5 microdiscectomy 08/20. Employer letter: HVAC technician, off work 03/13 to 06/30. |
| {{prior_history_and_social_media}} | Prior History and Social Media Material | Chiropractic note 2019: low back strain, discharged after 6 visits. Facebook post 05/24/2026: photo at a family cookout holding a grandchild. |
Expected Output
Part 1: conflicts between sources, a topic map with quoted record entries and risk areas, arithmetic, preservation questions for you, a checklist, declined statements and requests, missing information. Part 2: a plain-language client guide that opens with its title and carries no drafting note. Closes with an attorney-only Verification list.
Usage Notes
Use before the client is deposed. Paste the actual records, posts and surveillance material, not summaries, and any rule text on depositions or privilege from your court. Watch for the model drifting into model answers; the guide must coach process only. Read the document part line by line before it leaves the office, because it goes to the client: it must open with its title only, name nothing you told it to omit, and carry no placeholder explanation. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Double-check before use
- Check that the client guide opens with no note about what it leaves out.
These are the places where this prompt was seen to slip when tested on sample cases with a small AI model.
Legal Sources Referenced
- Fed. R. Civ. P. 30(d)(1) (default limit of one day of 7 hours for a deposition unless stipulated or ordered)
- Fed. R. Evid. 612 (writing used to refresh a witness before testifying: adverse party's rights apply only if the court decides justice requires them)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.