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)
| Variable | Description | Example |
|---|---|---|
| {{court_and_jurisdiction}} | Court and Jurisdiction | Court of Common Pleas, Philadelphia County, Pennsylvania (state court) |
| {{governing_expert_rules}} | Governing Expert Rules | Pennsylvania 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 Name | Dr. Alan Whitfield |
| {{expert_type}} | Type of Expert | IME physician |
| {{plaintiff_theory}} | Plaintiff Theory of the Case | Defendant 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 Report | Report 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 List | CV 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 Record | Primary 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
- Fed. R. Civ. P. 26(a)(2)(B) (a retained expert's report must contain a complete statement of all opinions and the basis and reasons for them, the facts or data considered, the witness's qualifications, a list of cases in which the witness testified during the previous 4 years, and a statement of compensation)
- Fed. R. Civ. P. 26(b)(4)(A) (a party may depose any person identified as an expert whose opinions may be presented at trial; if a report is required, the deposition may be conducted only after the report is provided)
- Fed. R. Evid. 702 (expert testimony is admissible if the proponent demonstrates it is more likely than not that the testimony is based on sufficient facts or data, is the product of reliable principles and methods, and reflects a reliable application of them to the facts of the case)
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.