Deposition Outline Generator
When preparing to depose a new witness and you want a structured outline that ties every line of questioning to a document or prior testimony and to the admissions your case theory needs.
A deposition outline is where case theory meets the witness. The goal is not a list of questions but a plan: which facts you need this witness to admit, which documents you need to authenticate or tie to them, and which answers you need to lock in before trial. Building that plan means reading the pleadings, the key documents and any prior testimony side by side, which is exactly the cross-referencing work that eats preparation time.
This prompt gives Claude your case theory, the pleadings, key documents in tagged blocks and any prior testimony, then asks for a topic-by-topic outline in a recommended order. Each topic has a goal, the exhibits to use, the quoted document line or testimony that supports it, open questions followed by leading lock-in questions, and the admissions to obtain. It ends with inconsistencies to explore, topics you may be missing and any assumptions Claude made.
The outline is a preparation aid, not a script. You know the witness, the judge and the strategic risks of each line of questioning, and you will adjust in the room. Time limits, exhibit procedures and objection practice depend on the governing rules and any stipulations, so confirm them yourself. Check every quoted basis against the original exhibit before relying on it.
The Prompt
I represent [PARTY ROLE], [CLIENT NAME], in [CASE NAME]. I am taking the deposition of [WITNESS NAME], [ROLE AND RELATIONSHIP TO THE PARTIES], on [DATE]. Time available: [HOURS, PER APPLICABLE RULE OR STIPULATION].
<case_theory>
[TWO OR THREE SENTENCES: WHAT WE MUST PROVE OR DISPROVE, AND WHERE THIS WITNESS FITS]
</case_theory>
<pleadings>
[PASTE THE OPERATIVE COMPLAINT AND ANSWER, OR RELEVANT EXCERPTS]
</pleadings>
<document name="[EXHIBIT NAME / BATES]">
[PASTE DOCUMENT TEXT]
</document>
[REPEAT FOR EACH KEY DOCUMENT]
<prior_testimony>
[OPTIONAL: PRIOR DEPOSITION EXCERPTS, DECLARATIONS OR INTERROGATORY ANSWERS BY OR ABOUT THIS WITNESS]
</prior_testimony>
[IF THIS IS AN ORGANIZATIONAL DEPOSITION: PASTE THE NOTICED TOPICS AND ORGANIZE THE OUTLINE BY TOPIC NUMBER]
Build a deposition outline organized by topic, in the order I should cover them, with one line explaining the order. Start with preliminaries (background, preparation for the deposition, documents reviewed) and end with a cleanup section.
For each topic give:
- Goal: what the topic must accomplish (an admission, a lock-in, foundation for an exhibit, or exhausting the witness's knowledge).
- Exhibits: by name or Bates number.
- Basis: quote the document line or prior testimony that supports this line of questioning.
- Questions: open questions first to gather facts, then short leading questions to lock in answers, plus exhaustion questions ("Anything else?") where we need the full universe.
- Admissions to obtain: short statements.
After the outline, list: (1) inconsistencies between the documents and prior testimony worth exploring, (2) topics I may be missing given the case theory, and (3) any assumption you made. Do not invent facts or quotes.
This is a draft for attorney review; I will adapt it to the witness and the governing rules.Example Output
A topic-by-topic deposition outline with goals, exhibits, quoted bases, open and lock-in questions, target admissions, and a list of inconsistencies and gaps to investigate.
Illustrative example — names, figures, and facts are fictional.
DEPOSITION OUTLINE: Regional Manager Paula Venn (fictional) Matter: Osei v. Tidewater Home Goods | Time: [7 HOURS IF FRCP 30(d)(1) APPLIES; OTHERWISE PER APPLICABLE RULE OR STIPULATION] Order: Start with routine reporting to build rhythm, then the March 2025 email before the witness sees where it leads, then the termination decision. TOPIC 1: PRELIMINARIES Goal: Background and preparation. Questions: What did you review to prepare? Who did you meet with? (Do not ask for privileged content.) TOPIC 2: STORE REPORTING STRUCTURE Goal: Lock in that Venn approved all terminations in Region 4. Exhibit: THG000102 (Region 4 org chart). Basis: THG000102: "All separations require RM approval." Questions: Describe your duties in 2025. / You approved every separation in Region 4 in 2025, correct? / No separation happened without your sign-off, correct? Admission: Venn approved Osei's termination. TOPIC 3: MARCH 12, 2025 EMAIL Goal: Establish knowledge of the complaint before the decision. Exhibit: THG000441. Basis: THG000441 (Venn to HR, Mar. 12): "Osei filed another complaint. Let's talk about next steps." Questions: You wrote this email? / "Another complaint" refers to Osei's February 28 complaint? / Before March 12 you knew Osei had complained to HR, correct? / What did you mean by "next steps"? / Anything else discussed? Admissions: Venn knew of the complaint by March 12; the termination followed on March 20. INCONSISTENCIES TO EXPLORE - Interrogatory answer 6 says the decision was made "in early February," but THG000441 suggests it was still open on March 12. POSSIBLY MISSING - No document shows who drafted the termination memo. ASSUMPTIONS - I assumed "complaint" in THG000441 refers to the February 28 HR complaint; confirm. All names and facts are fictional and illustrative.
Tips
- •Write the case theory block carefully; the outline's goals and admissions are only as focused as the two or three sentences you give it.
- •Include prior testimony from other witnesses about this person; the inconsistency list is often the most valuable part of the output.
- •Reuse questions from earlier depositions with the reuse-deposition-questions workflow, then paste them in as prior testimony context.
- •Confirm time limits and any stipulations about exhibits before the deposition; the prompt keeps them as placeholders.
- •Treat the outline as a draft for attorney review and verify every quoted basis against the original exhibit.
Frequently Asked Questions
How is this different from the deposition summary prompt?
They sit on opposite sides of the deposition. This prompt prepares you to take a deposition by organizing topics, exhibits and target admissions. The deposition summary generator works from a finished transcript to record what the witness actually said. Many lawyers run the summary of an earlier witness and paste it into this prompt as prior testimony.
Will Claude write leading questions for a friendly witness?
Tell it which kind of witness you are examining. The default structure, open questions followed by leading lock-in questions, suits an adverse or neutral witness in a discovery deposition. For your own witness, or a deposition you plan to use at trial, say so in the case theory block and ask for non-leading questions; the governing evidence rules will shape what is permitted.
Can I trust the quoted bases?
Treat them as pointers to check, not as verified quotes. Claude is told to quote only from the documents you paste and not to invent facts, but you should confirm every quote against the original exhibit before relying on it in the room. A misquoted document read to a witness can cost credibility on the record.
What if I have hundreds of documents?
Paste the documents that matter for this witness, not the whole production. Use a chronology or a coding table to identify the key exhibits first, then build the outline from those. If you need broader context, summarize the remaining documents in the case theory block rather than pasting everything.
Related Prompts
Get New Prompts Like This Every Week
Join the free Claude for Lawyers newsletter — weekly prompts, tutorials, and practice-specific guides.