Prompt Pilotby Write.law
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Build a prep plan for this witness

Turns one witness's actual tendencies and the actual exhibits into a three-session prep plan: the questions they will really be asked, answers in their own voice, and drills for the habits that will hurt them.

About 15 minintermediateLitigation

Your prompt5,153 characters

Still to fill in: The witness, Topics and exhibits, Forum and rules

RoleYou are a trial lawyer who has prepped hundreds of witnesses and watched two of them talk their way into a verdict for the other side. You prep habits, not scripts: a memorized answer collapses on the second follow-up and sounds like a lawyer wrote it, because one did. You spend your prep time on the three questions the witness dreads, and you refuse to put a phrase in a witness's mouth they would not use on their own.What I needBuild a prep plan for The witness ahead of the Fact deposition in Forum and rules. I have One 90-minute session only to work with.InputsThe witness: The witness Setting: Fact deposition Forum and rules: Forum and rules Prep time available: One 90-minute session only Topics and exhibits: Topics and exhibitsHow to work this1. Name the two tendencies in The witness that will cost us in the Fact deposition and write a drill for each: an exercise with a rep count or a clock, not advice. 2. Lay out the sessions with a purpose, a length, and a deliverable each. If One 90-minute session only will not hold three sessions, say which one you dropped and what we lose. 3. For every exhibit in Topics and exhibits, decide whether the witness sees it and in which session. Flag any document you would not put in front of them, and why. 4. Write the ten hardest questions this witness will face, in the examiner's voice. For each: a calibrated answer in this witness's own register, and the trap. Keep answers under two sentences unless you justify the length. 5. State the rules of this proceeding as rules the witness must know cold: objections, instructions not to answer, errata, the Forum and rules time limit, how to ask for a break. 6. Give logistics as a checklist: time, place, dress, what to bring, what to leave home, phone. 7. Mark the plan privileged, then say what is discoverable anyway in Forum and rules: the fact of prep, the documents reviewed, and break conversations.Close with these four sections, every time, without being askedAssumptions I made. Every assumption about what this witness knows, authored, or has already said under oath. Mark each [verify] or [safe]. Flag every calibrated answer that assumes a fact I did not give you. Where this is weakest. The two or three prepared answers most likely to fail on the second follow-up, and the drill that is thinnest. Name the question number, not "the mock exam generally." What only you can decide. The calls I left to you, each as options with tradeoffs. At minimum: whether to show this witness their worst exhibit in prep: doing it rehearses the hardest moment of the day but in many forums opens the review to examination and can put your selection of documents in play under FRE 612, while withholding it keeps prep clean and lets the witness meet the document for the first time on video. And whether to let a shaky memory stand as "I do not recall" or reconstruct it from documents: the first is safe and looks evasive on a transcript read to a jury, the second is persuasive and locks the witness to a version they may not hold up under cross. What would make this materially better. What I could give you that would sharpen the next pass most: prior deposition or declaration text from this witness, the actual notice topics, the exhibits themselves, or the examiner's style from a prior case. Rank by impact.Output formatHeaded [PRIVILEGED - ATTORNEY WORK PRODUCT]. Sessions with purpose, length, and deliverable; a ten-row table of Question / Calibrated answer / Trap; a show-or-withhold call for each exhibit; the rules of the room; logistics; and coaching notes written to this witness by name. Then the four closing sections.Never do this- If this plan would fit any witness in any case, it is too generic. Rebuild it from what The witness is actually like and what is in Topics and exhibits. - No hedging filler. Cut "arguably," "it should be noted," "remain calm," and "be truthful" as substitutes for a drill. Do not tell me to consult an attorney. I am the attorney. - Every rule, time limit, exhibit number, and case reference must come from my inputs or be marked [UNVERIFIED - confirm before the session]. Never invent an exhibit number or a standing order. - Where you do not know what this witness has already said under oath, say you do not know rather than smoothing it over. A calibrated answer that contradicts prior testimony is worse than no prep. - Do not pad. A tight two-session plan beats a twelve-page binder nobody works through. Length is not value.Before you answer- Is every drill something the witness does, with a count or a clock on it? - Are the ten questions phrased the way opposing counsel would, or the way I would? - Does every calibrated answer sound like this witness, or like a lawyer? - Would this plan be useless for a different witness in this same case? It should be. - Is any exhibit number, rule cite, or prior statement here something I generated rather than was given?

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.

One sentence is all it takes. Plaintiff's counsel needs a single quotable line for the summary judgment opposition, and she will spend the first hour on friendly background to get it: every document read, tone warm, no visible pressure. Take that side of the table as the examiner. Name the three moments where this witness gives it up, quote the question you would ask, and rewrite the drill that would have prevented it.
3

Go deeper

Pushes the work further once the basics are right.

Nothing said in a conference room survives the drive to court unless it is on paper. Produce the one-page card the witness holds during prep and reads in the car: three rules, the five pitfalls specific to this witness, the three reset phrases they can use in their own words, and the two exhibits they should expect first. Plain language, no legal terms, nothing they would be embarrassed to have read aloud if it were left on the table.

Before you run it

What to gather first

  • The witness's role, what they actually know, and how they behave under pressure
  • Prior testimony, declarations, or interview notes from this witness
  • The exhibits they will be shown and which ones they authored
  • The deposition notice or 30(b)(6) topic list
  • Time limits, standing orders, and the judge or arbitrator's habits

Watch for

  • Prep is work product, but the fact of preparation, the documents shown to the witness, and any writing used to refresh recollection can be fair game under FRE 612 and its state analogues. Decide what the witness sees with that rule in front of you.
  • Never script. A rehearsed answer collapses on the second follow-up, and a witness who sounds coached will be asked, on the record, who told them to say that.
  • A 30(b)(6) designee testifies for the entity and must be educated on topics beyond personal knowledge. This plan prepares a person; it does not discharge the entity's duty to prepare a designee.
  • Many judges and some jurisdictions prohibit conferring with a deponent while a question is pending or during breaks. Confirm the standing order before you plan a mid-deposition huddle.
  • The model does not know what this witness said in prior testimony, declarations, or their own emails. Reconcile every proposed answer against the existing record before the session.

What comes back

A privilege-marked plan: sessions with purpose, length, and a deliverable each; a ten-row table of the hardest questions with Question / Calibrated answer / Trap; a show-or-withhold decision for every exhibit; the rules of the proceeding stated for the witness; a logistics checklist; and two or three coaching notes written to this witness by name. Closes with Assumptions / Where this is weakest / What only you can decide / What would make this better.

See an example of what you’ll get
[PRIVILEGED - ATTORNEY WORK PRODUCT - PREPARED IN ANTICIPATION OF LITIGATION] Witness: A. Delgado, CHRO, Meridian Logistics; 30(b)(6) designee, Topics 1–4 Setting: 30(b)(6) deposition, N.D. Cal., seven-hour limit under Rule 30(d)(1) The two habits that will cost us 1. *She over-explains.* On Topic 2 she will try to justify the HR process rather than describe it. Drill: twenty rapid questions, answers capped at fifteen words, run twice, second round on video so she watches herself. 2. *She gets defensive when challenged.* Reyes will challenge her on Ex. 9 within the first ninety minutes. Drill: the same three hostile questions asked six times in a row, escalating tone, until her answer stops changing. Sessions *(two available; the day-before refresher was cut; we lose the last-mile settling, so move logistics into Session 2)* - Session 1: Briefing, 90 min. Theory in plain English; her role as designee versus as a fact witness; walk Ex. 14 and Ex. 22. Deliverable: she can state Meridian's position on Topic 1 in three sentences. - Session 2: Mock exam, 3 hrs. Full run on Topics 1–4 with a colleague she has never met playing Reyes. Video the first hour. Deliverable: fifteen-word average answer length, plus the logistics card. The ten hardest questions (excerpt) | Question, in Reyes's voice | Calibrated answer | The trap | |---|---|---| | "You wrote in 2023 that Ms. Ashford was your strongest operator, didn't you?" | "I did." | Any explanation here is an argument. Concede and stop. | | "What changed between that memo and March 2025?" | "The operational results changed. I can walk you through the quarters if that's helpful." | She wants to attack Ashford personally. Keep it to the numbers. | | "Who decided to terminate her?" | "Mr. Okafor made that decision." | Do not speculate about his reasons. That is Topic 1 for him, not her. | | "You don't have a single written warning before March 3, do you?" | "Not a formal written warning, no." | Do not manufacture documentation or say "but there were verbal conversations" unless asked. | Document decisions - Ex. 14, Ex. 22: show in Session 1. She authored neither; no refreshed-recollection issue. - Ex. 9: show, but flag: it is her own memo, so Rule 612 exposure is limited, and meeting it cold on video is worse. - Draft investigation memo (unproduced): withhold. Showing it in prep invites a line of questioning about a document we have not produced. Rules of the room. Seven hours on the record. Answer only the question asked. If our objection is "form," answer anyway. If we instruct you not to answer, stop mid-sentence. You may ask for a break at any time except while a question is pending. Judge Chhabria's standing order means we cannot confer then, and Reyes will ask whether we did. Coaching notes to Delgado. Silence is Reyes's tool, not yours. When she pauses after your answer, let it sit. You are not there to be liked. "I don't know" and "I don't recall" are complete answers and you will need both on Topic 3. --- Assumptions I made. That Delgado authored Ex. 9 [verify - changes the Rule 612 analysis]. That Okafor, not Delgado, made the termination decision [verify - if she participated, four of these answers are wrong]. That she has not been deposed or declared in this matter before [verify - this is the one that most worries me]. That the seven-hour default applies with no stipulation extending it [safe absent a stipulation]. Where this is weakest. Question 4 ("you don't have a single written warning"), the calibrated answer is honest but leaves her one follow-up from volunteering the verbal-coaching story, which is her instinct and which nobody can corroborate. Drill it separately. The comparator questions on Topic 3 are also thin because I do not have the comparator data. What only you can decide. Whether Delgado is the right designee for Topic 1 at all. She is credible and knows the HR process, but she did not make the decision, so every Topic 1 answer will be secondhand and Reyes will move to compel a second designee, which costs you a day and puts Okafor in the chair. Designating Okafor now controls the narrative but exposes your worst witness. Also yours: whether to prepare her to reconstruct the March 1 conversation from her notes or to leave it at "I don't recall": reconstruction is more persuasive and locks her to a version she may not hold under cross. What would make this materially better. (1) Delgado's prior declaration, if one exists: it is the single largest gap in this plan. (2) The full 30(b)(6) notice text, so I can check the plan against the actual topic language rather than your summary. (3) The comparator discipline data for Topic 3.
Why this prompt is built the way it is
## Framework 1. **Prep the habit, not the answer.** Name this witness's two costly tendencies and design a drill for each. "Stay calm" is not a drill; "answer these twelve questions in under fifteen words each, twice" is. 2. **Three sessions with a purpose.** Initial briefing, mock examination, day-before refresher. Each gets a length and a deliverable. 3. **Decide what they see.** Every document is a choice: showing it rehearses the hard moment and may open the review to the other side; withholding it means they meet their worst exhibit on the record. 4. **The ten hardest questions, in the examiner's voice.** Phrased the way opposing counsel will phrase them, not the way you would. 5. **Answers short, true, and unscripted.** Past two sentences, cut it or justify the length. 6. **The rules of this room.** Objection practice, instruction not to answer, errata, time limits, breaks, stated as rules the witness must know cold. 7. **Mark it privileged and say what leaks anyway.** The fact of prep, the documents reviewed, and in some forums the break conversations.