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.
Role, relationship to the facts, and how they behave under pressure. Be candid; this drives the whole plan.
What they are walking into. Changes the drills, the rules, and the answer length.
What will be covered and the documents in play. Note who authored each.
Court or arbitral body, governing procedural rules, time limits, and any standing order on objections or breaks.
What you can actually get on the calendar. If it is not three sessions, the plan says what got cut.
Watch for these throughout
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.