Defendant Driver Deposition Outline for a Motor Vehicle Accident Case (Claude)
Builds a defendant driver deposition outline in XML-structured form from the police report, statements and records you paste. Impeachment points quote their source, no prior testimony is invented, and the questions to be asked aloud are kept clean.
The Prompt
Variables (8)
| Variable | Description | Example |
|---|---|---|
| {{defendant_driver_name}} | Defendant Driver Name | Karen Whitfield |
| {{court_and_governing_rules}} | Court and Governing Rules | Circuit Court for Baltimore County, Maryland. Pasted: the deposition rule text and the scheduling order dated 09/03/2026. |
| {{key_disputes}} | Key Disputes | Who had the green light; speed on approach; whether the defendant was using her phone. |
| {{attorney_instructions}} | Attorney Instructions | Commit her to her speed and signal phase before showing the phone records. |
| {{police_report}} | Police Report | Report 26-044117: "Unit 2 stated she had a green light." No citation issued to either driver. |
| {{defendant_statements}} | Defendant Statements and Discovery Responses | Interrogatory 7 answer: "I was traveling approximately 30 mph and looked left before entering." |
| {{plaintiff_and_witness_accounts}} | Plaintiff and Witness Accounts | Client: "My light was green; I was already in the intersection." Witness Alvarez: "The SUV never slowed." |
| {{records}} | Phone Records, EDR Data and Vehicle Documents | Carrier log: outgoing text 14:31:52; EDR 5 seconds pre-impact speed 41 mph. |
Expected Output
An analysis block, then Part 1 written out in full (evidence register, conflicts, arithmetic, a question table naming the document for each impeachment, declined items, missing information) and Part 2 (numbered marker-free deposition questions by section). Closes once with an attorney-only Verification list.
Usage Notes
Use after the police report, the defendant's written discovery responses and any phone or event data recorder records are in hand. Paste actual text with page references. Watch for impeachment lines that quote a prior statement the sources do not contain, and for questions that assume the answer to a disputed fact. Read the document part line by line before it leaves the office; the questions are read aloud, so they must carry no notes or exhibit cues. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
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)
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.