Deposition Question Outline for a Named Witness From Your Documents
Builds a topic-organized deposition outline for one witness from the exhibits and prior statements you paste. The questions are marker-free and tied to the documents; contradictions between the witness's own statements are set out quoted for you, not argued.
The Prompt
Variables (7)
| Variable | Description | Example |
|---|---|---|
| {{witness_name}} | Witness Name | Daniel Whitfield |
| {{witness_role}} | Witness Role | Regional sales director of the defendant company |
| {{case_caption}} | Case Caption and Court | Northgate Supply v. Brightline Systems, No. 25-CV-2210, Superior Court |
| {{documents}} | Documents and Exhibits | Ex. 4, Distribution Agreement dated Mar. 3, 2023, para. 6: "Brightline shall deliver within 30 days." Ex. 7, email from D. Whitfield to N. Ruiz, June 2, 2024: "We shipped on May 20." |
| {{prior_statements}} | Prior Statements of the Witness | Interrogatory answer no. 3, Aug. 9, 2025: "I first learned of the delay on June 10." |
| {{instructions}} | Known Facts and Attorney Instructions | Topics in order: role, the agreement, shipment, the June emails. Do not ask about settlement talks. Two hours available. |
| {{rule_text}} | Governing Rule Text | Paste verbatim any rule on deposition length or conduct that you rely on. |
Expected Output
Part 1 attorney-only notes (document register, conflicts and impeachment candidates quoted, count and time checks, cleared and held-back lists, question map, form flags, unsupported statements declined, declined requests, missing information). Part 2: numbered questions to ask aloud by topic. Then a verification list.
Usage Notes
Use it once you hold the documents the witness will be examined on. Paste each document or excerpt with its exhibit label and date, any prior statements of the witness, and your instructions and known facts. Failure mode to watch: a question that assumes a fact no document states, or a question that gives away a contradiction you wanted to save; the questions should stay open on any point where the papers conflict. Read the document part line by line before it leaves the office. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Originally featured in: ChatGPT Prompts for Lawyers: The Complete Guide
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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.