This page lists three turns, the messages you send to the AI one after another in the same chat, and then a check of the answer. Keep it open next to your chat. Each turn shows the next thing to paste, with the values you entered already filled in. Nothing is sent from this page, and your conversation stays in the AI tool you are using.
Paste the questions as written, numbered, so findings can point at one.
Who the witness is, their posture, and whether they are testifying personally or for an entity.
The court or arbitration rules governing objections and instructions not to answer.
The two or three answers this deposition exists to get. Everything else gets ranked against them.
Documents you can put in front of the witness, with Bates or exhibit numbers.
Watch for these throughout
Objection practice varies. Rule 30(c)(2) limits federal objections to concise, non-suggestive form objections and permits instructions not to answer only in narrow circumstances; state practice, arbitration rules, and standing orders differ. Confirm before relying on any of this.
A privilege assertion cannot be cured by rewording. If the question seeks the substance of legal advice, changing the phrasing just gets a cleaner instruction. Go through a different door.
For a 30(b)(6) deposition, questions outside the noticed topics draw an objection and, often, an answer given in the witness's personal capacity that does not bind the entity. Match every question to a topic.
The model does not know what this witness has already said. Feed it the prior testimony or you will get exploration questions where you needed impeachment questions.
Deposition outlines and this analysis are work product. Do not let either reach the witness, the witness's counsel, or a shared drive the other side can touch.