Prompt Pilotby Write.law
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Analyze/Featured

Pull admissions and impeachment from a deposition

Separates real admissions from testimony you happen to like, catches the contradictions against your exhibits, and puts a page:line cite on every quote.

About 20 minintermediateLitigation

Your prompt5,358 characters

Still to fill in: Transcript, Witness, Case theme

RoleYou are a trial lawyer who reads transcripts the way a film editor watches dailies: hunting for the four seconds that make the cut, and equally alert to the moment that gets played against you. You know the difference between an admission and testimony you happen to like, and between "I don't recall" and a denial. You will not quote a line you cannot tie to a page and line.What I needWork the deposition of Witness for admissions, contradictions, and impeachment, measured against this theme: Case theme. Cross-check the testimony against Documents to cross-check and flag how Court affects what I can actually use.InputsTranscript: Transcript Witness: Witness Case theme: Case theme Documents to cross-check: Documents to cross-check Court: CourtHow to work this1. Read for sequence before pulling anything. Note where the story shifts and what preceded it: a question, a break, a document, an objection. 2. Pull admissions, applying a hard test: does this testimony establish an element, foreclose a defense, or contradict a pleading? If it only sounds good, it goes under "helpful color" or nowhere. 3. Separate internal contradictions (the witness against the witness) from extrinsic ones (the witness against a document in Documents to cross-check). For every extrinsic contradiction, quote the testimony and the document language side by side. 4. Pull impeachment: bias and financial interest, prior inconsistent statements, and any place an objection or a break changed the answer. Mark each material or merely irritating. 5. Never score "I don't recall," "not that I'm aware of," or "I'd have to check" as a denial. Track them as memory gaps and note whether the examiner locked each one in with a follow-up. 6. Put a page:line cite on every quotation, taken only from Transcript. Where the cite is not in what I pasted, write [CITE UNAVAILABLE] rather than approximating. Never construct a page number. 7. Rank every finding by whether it survives on paper without you narrating it, and note where Court's rules (hearsay, prior inconsistent statement, party-opponent) change what is usable.Ask me firstBefore you produce anything, ask me these questions, then stop and wait: 1. What is this workup for: a summary judgment motion, a mediation brief, a trial cross outline, or a decision about whether to take a second session? The same transcript yields different pulls for each. 2. Which exhibits used with Witness are already authenticated or admitted, and which are still contested? A contradiction is only worth having if the document behind it can come in. 3. Has an errata sheet been served, and is this the corrected transcript? Errata can erase the best line in the deposition. 4. What is the one fact you needed from this witness and did not get, so I can tell you whether it is buried somewhere in here. Do not begin until I answer. If I tell you to proceed anyway, state each assumption at the top of your output and mark it [ASSUMPTION - verify].Output formatHeadline finding: one sentence, the thing that changes how I value this case. Admissions - table: topic, verbatim Q&A, page:line, and the element or defense it reaches. Contradictions: internal and extrinsic in separate tables, each quoting both sides with cites. Impeachment material: list with cites, marked material or cosmetic. Memory gaps: every "I don't recall," with cite, marked locked in or open. Three lines for the trial graphic: the quotes that work with no explanation. What we did not get: evaded topics, cut-off questions, and the follow-up that would close each open admission. End with one line naming the two of my answers that most changed this workup: which admission or contradiction you would have ranked differently, or left out, without them. If an answer changed nothing, say so; it means I should not have been asked.Never do this- If your findings would read the same for any case with any witness, they are too generic. Every entry ties to this theme and this witness's words. - No hedging filler. "Arguably damaging" and "this could be significant" are not findings. Say what it proves and to what. Do not tell me to consult an attorney about my own deposition; I am the attorney. - Never invent, extrapolate, or round a page:line cite, and never paraphrase inside quotation marks. Anything you cannot locate in Transcript gets [CITE UNAVAILABLE] or [UNVERIFIED - check the certified transcript]. - Where the excerpt does not show what preceded an answer, say you do not know the context rather than assuming the question. Do not smooth over a gap in the record with fluent narration. - Do not pad. Two real admissions beat nine entries of testimony you liked. Length is not value.Before you answer- Does every quotation carry a page:line drawn from the pasted text? - Is each admission tied to an element, a defense, or a pleading, or did I promote something I merely liked? - Did I treat any "I don't recall" as a denial? - For each extrinsic contradiction, did I quote the document language rather than describing it? - Would this workup be useless in another case? It should be.

Adds driver's-seat tunes: options instead of answers, questions before work, every citation flagged. Your values come with it.

2

Pressure-test it

Makes the AI switch hats and attack its own answer.

Somewhere before trial, defense counsel sits down with Witness for four hours and works through exactly this material. Take that chair. For each admission, write the rehabilitation question that defuses it and the answer you would coach as the lawyer running that session. Then tell me which admissions survive rehab, which ones I have to lock down with a document before trial, and which one I should stop relying on entirely.
3

Go deeper

Pushes the work further once the basics are right.

When Witness says something different at trial, this outline is what I reach for. Build the ten-question trial cross outline: leading questions only, sequenced so the admissions are locked before the witness sees where the line of questioning is going. Put the exhibit and page:line behind each question so I can impeach the moment the answer changes.

Before you run it

What to gather first

  • The transcript text or the relevant excerpts, with page and line numbers intact
  • The witness's name and role, and whether they are adverse or yours
  • Your one-sentence case theme
  • The exhibits used, and which are authenticated or already admitted
  • Whether an errata sheet has been served

Watch for

  • The model fabricates page:line cites, and confidently. Check every one against the certified transcript before designating or filing.
  • Errata sheets change testimony. Confirm you are working from the corrected transcript, and check whether the errata itself is worth using.
  • "I don't recall" is not a denial, and courts treat the two very differently at summary judgment. Watch for the model collapsing them.
  • Testimony subject to a sustained objection or an instruction not to answer may be unusable. Check the objection log before relying on any pull.
  • Deposition transcripts are usually confidential under a protective order. Confirm your firm's AI policy and the order's terms before pasting one.

What comes back

A one-sentence headline finding, an admissions table tied to elements and defenses, separate internal and extrinsic contradiction tables quoting both sides, impeachment material marked material or cosmetic, a memory-gap list marked locked in or open, three trial-graphic quotes, and what the examination failed to get, every quote carrying a page:line cite.

See an example of what you’ll get
*(After you answer the four questions, say, this is for opposing summary judgment; Exs. 9, 14, and 22 are authenticated; errata served with no substantive changes; you never got a direct denial of retaliation.)* Headline finding. Chen admitted the CEO ordered the termination and that Reyes had never been formally disciplined before the March 3 complaint, and her account of Reyes's performance moves between direct and cross. That is a prima facie case built out of the defense's own HR witness. Admissions | Topic | Testimony | Cite | Reaches | |---|---|---|---| | Knowledge of protected activity | Q: "You learned of Reyes's HR complaint on March 3?" A: "Yes." | 47:12-14 | Element 2: employer knowledge | | No prior discipline | Q: "You never disciplined Reyes before March 3?" A: "Not formally, no." | 92:6-9 | Rebuts the legitimate-reason defense | | Decision-maker | Q: "Who made the decision?" A: "Mr. Hayes told me to do it." | 118:21-24 | Causation; also identifies the real decision-maker for the cat's-paw argument | Contradictions: internal - Direct: "Performance had been declining for months." (33:4) against cross: "Not formally, no." (92:6). She never reconciles the two, and no document supports the first. Contradictions: extrinsic - Testimony: "I do not recall any wage complaints." (61:18) against Ex. 14, Reyes's March 3 email to Chen: "This is my third complaint about overtime." Chen is the named recipient. Impeachment material - Bias, material: Chen received a $120,000 retention bonus tied to the quarter in which the termination occurred (Ex. 22; 134:8-16). - Prior inconsistent statement, material: Chen's own 2023 review of Reyes calls her a "top performer" (Ex. 9), which is hard to square with 33:4. - Cosmetic: Chen could not remember her direct reports' titles (28:3). Annoying, proves nothing. Memory gaps - "I do not recall any wage complaints." (61:18): open. No follow-up put Ex. 14 in front of her, so she can adopt it at trial without contradicting herself. - "I'd have to check the file." (88:22): open. Three lines for the trial graphic 1. "Mr. Hayes told me to do it." (118:24) 2. "Not formally, no." (92:9) 3. "This is my third complaint about overtime." (Ex. 14) What we did not get. No direct denial of retaliatory motive. The question was never asked in those words. Nothing on the relationship between Chen and co-VP McAllister. Nothing on whether retention was discussed before March 3, which would date the performance narrative. The follow-up that would have closed 61:18: hand her Ex. 14 and ask her to read the subject line aloud. Assumptions. I treated 92:6-9 as covering formal and informal discipline; "not formally" leaves room for a verbal-warning argument [ASSUMPTION - verify against the personnel file]. What your answers changed. "This is for opposing summary judgment" is what put 118:21-24 at the top of the admissions table. For a trial cross outline I would have led with the Ex. 9 impeachment instead, because it plays in front of a jury and a decision-maker admission only reads. That Exs. 9, 14, and 22 are authenticated is why the extrinsic contradiction at 61:18 and the retention-bonus bias finding are ranked as usable rather than contingent; with Ex. 14 still contested, 61:18 drops to a footnote and the headline changes. Your errata answer changed nothing here, but it is the answer that would have voided half this workup, so it was worth asking.
Why this prompt is built the way it is
## Framework 1. **Read for sequence first.** Note where the witness's story changes and what preceded the change: a question, a break, a document. 2. **An admission establishes an element, forecloses a defense, or contradicts a pleading.** Testimony you merely like is not an admission. 3. **Two kinds of contradiction, kept apart.** Internal (witness against witness) and extrinsic (witness against a document). Quote both sides of an extrinsic one. 4. **Impeachment is bias, prior inconsistency, and memory failure**, and only counts if it goes to something that matters. 5. **"I don't recall" is not a denial.** Track memory gaps separately and note whether each was locked in with a follow-up. 6. **Page:line on everything.** A cite that is not in the source is unavailable, not approximated. 7. **Close with what you did not get.** The evaded topics, the cut-off questions, and the follow-up that would have locked each admission.