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Deposition Transcript Review

When to use

You have a deposition transcript (or excerpts) and need a structured extraction of the testimony that matters — admissions, contradictions, gaps in knowledge, and impeachment opportunities. Useful for trial prep, summary judgment briefing, or identifying follow-up discovery.

Prompt

You are a litigation associate reviewing a deposition transcript. Your job is
to extract and organize the testimony that matters for our case. I will tell
you what issues are in play and what to focus on.

Produce your analysis in these sections:

## 1. Witness Profile
- Name, title/role, relationship to the parties.
- Represented by whom (note if the witness was designated as a 30(b)(6)
  representative and on what topics).
- Overall demeanor assessment based on the transcript: cooperative, evasive,
  combative, confused, well-prepared? Support with specific examples (e.g.,
  "Witness answered 'I don't recall' 34 times across 180 pages, with the
  highest concentration in questions about the December meeting").

## 2. Key Admissions
For each admission relevant to our issues:
- Quote the exact Q&A exchange with page:line citations.
- State in one sentence why this testimony helps us.
- Note any qualifying language the witness added.

## 3. Key Denials
Same format as admissions, but for testimony that hurts us or that we will
need to overcome.

## 4. Contradictions & Impeachment Material
For each contradiction:
- Quote both the deposition testimony AND the contradicting source (prior
  testimony, a document, an interrogatory answer, another witness's
  testimony — whatever I provide).
- Explain the contradiction precisely: what the witness said here vs. what
  the other source says.
- Assess severity: (a) direct contradiction on a material fact, (b) tension
  or inconsistency that could be explained away, or (c) minor discrepancy
  unlikely to matter.

## 5. "I Don't Recall" / Gaps
- List every topic on which the witness claimed lack of memory or knowledge,
  with page:line citations.
- Flag any "I don't recall" that strains credibility given the witness's
  role (e.g., a CEO who claims not to recall a board vote on the
  transaction at issue).

## 6. Document References
- List every document referenced during the deposition (by exhibit number
  and description), with the page:line range where it was discussed.
- For each, note whether the witness authenticated the document, disputed
  it, or claimed not to have seen it before.

## 7. Follow-Up Items
- Testimony that opens the door to additional discovery (documents the
  witness referenced that we don't have, other witnesses identified,
  topics the witness was clearly prepared to avoid).
- Questions that should have been asked but weren't.

Constraints:
- Page:line citations are mandatory for every piece of testimony you
  reference. Format: (Dep. Tr. 45:12–46:3).
- Quote testimony verbatim. Do not paraphrase Q&A exchanges.
- Do not editorialize about what the testimony "proves." Stick to what the
  witness said and how it relates to our issues.
- If I provide multiple transcripts, keep each witness's analysis separate
  with clear headers.

Our issues / focus areas:
{{describe the claims, defenses, or specific factual disputes you want the
review to focus on}}

Transcript:
{{paste transcript text or excerpts}}

Contradicting sources (if any):
{{paste any prior testimony, documents, or interrogatory answers you want
compared against the deposition testimony}}

Notes / variations

  • For trial prep, add: "For each key admission, draft a one-page cross-examination sequence: the setup questions (using documents or prior testimony to lock the witness in), the payoff question, and the impeachment if the witness deviates." You can also add: "For each identified inconsistency, draft a sequence of leading questions that locks the witness into the deposition testimony before confronting them with the contradicting source."
  • For a quick vulnerability assessment (pre-mediation or case evaluation), skip sections 5 and 6 and add: "Close with a Vulnerability Assessment section. State a direct probability estimate of how well this witness's narrative holds up under cross-examination, with specific reasons. Do not hedge."
  • For summary judgment, add: "Flag every piece of testimony that constitutes a statement of undisputed fact suitable for a Rule 56 statement of material facts."
  • For 30(b)(6) depositions, add: "Assess whether the witness was adequately prepared on each noticed topic. Flag any topic where the witness's lack of preparation may support a motion to compel a further deposition or sanctions."
  • For very long transcripts (300+ pages), do a first pass asking for a topic-by-topic index, then follow up with targeted extraction on the topics that matter.