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Claude Prompt: Deposition Outline for a Defense Expert in a Personal Injury Case

Builds a deposition outline for a defense IME physician, biomechanical engineer or accident reconstructionist from the report and CV: bias, materials not reviewed, methodology, and every assumption set against the quoted record.

The Prompt

Variables (8)

VariableDescriptionExample
{{court_and_jurisdiction}}Court and JurisdictionCourt of Common Pleas, Philadelphia County, Pennsylvania (state court)
{{governing_expert_rules}}Governing Expert RulesPennsylvania Rule of Civil Procedure 4003.5 and Pennsylvania Rule of Evidence 702 (text pasted below); case management order dated 09/08/2025 permitting expert depositions by agreement.
{{expert_name}}Expert NameDr. Alan Whitfield
{{expert_type}}Type of ExpertIME physician
{{plaintiff_theory}}Plaintiff Theory of the CaseDefendant ran a red light and struck the driver side of plaintiff's car; the collision caused a C5-C6 disc herniation that required a fusion on 09/18/2025.
{{expert_report}}Expert ReportReport of Dr. Whitfield dated 11/20/2025, 14 pages. Page 9: "The cervical findings are degenerative and pre-existed the collision." Page 3: records reviewed.
{{expert_cv_and_testimony_list}}Expert CV and Testimony ListCV dated 2025: board certified in orthopedic surgery 1998; no surgical privileges listed after 2016. Testimony list: 38 depositions in the last four years.
{{case_record}}Case RecordPrimary care record 06/11/2024, p. 2: "No neck complaints. Full cervical range of motion." MRI report 04/02/2025: "C5-C6 left paracentral disc herniation." Plaintiff deposition 10/02/2025, 58:3-14.

Expected Output

An analysis block extracting the opinions, assumptions, materials and arithmetic, then an outline in eleven parts: (A) qualifications and bias questions; (B) materials reviewed versus not reviewed; (C) methodology questions, ending with a block of at least four questions on every standard or publication the report cites; (D) conflicts between the report's assumptions and the quoted record; (E) concessions to obtain; (F) impeachment material with a drafted question for each item; (G) questions for your own expert; (H) recomputed figures; (I) unsupported statements declined; (J) declined requests; (K) missing information. A verification list closes the output.

Usage Notes

Use when the defense report, the CV and testimony list, and the relevant records are in hand. Paste the report in full, with page numbers, and the record passages you believe the expert ignored. Failure modes to watch for: a question that puts words in the expert's mouth, and a standard or study cited in the report being treated as real; the outline asks the expert to identify and produce every cited source, and each one sits on the verification list until you have it in hand. The prompt will not supply medical or engineering counterpoints from memory, so route the items in part G to your own expert. The federal rules listed are reference points and do not govern a state-court case. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.

Legal Sources Referenced

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.