30(b)(6) Topic Coverage Map
Map a corporate designee's testimony against every noticed topic — and flag the topics left unaddressed or met with 'I wasn't prepared on that.'
24 expert litigation prompts for depositions, medical records, discovery, expert reports, and full case files. Each one sets the context, the task, the output format, and a page-and-line citation rule.
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Three guides with a complete sample prompt, source rules, and a verification checklist.
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Build a date-ordered medical chronology from the complete record, with source citations for every encounter and explicit flags for treatment gaps, prior history, causation language, and missing records.
Open the guideTurn a complete deposition transcript into a topic-based page-line summary with precise cites, verbatim excerpts, admissions, exhibits, and unanswered questions.
Open the guideTurn the verified case record into a topic-based deposition outline with fact-locking goals, record-cited exhibits, conflict probes, and open-to-closed question sequences.
Open the guideShowing all 24 templates
Map a corporate designee's testimony against every noticed topic — and flag the topics left unaddressed or met with 'I wasn't prepared on that.'
Pull every admission, damaging concession, and 'I don't know' on your key issues out of a transcript — with verbatim Q&A and page:line cites.
Turn the verified case record into a topic-based deposition outline with fact-locking goals, record-cited exhibits, conflict probes, and open-to-closed question sequences.
Build a date-ordered medical chronology from the complete record, with source citations for every encounter and explicit flags for treatment gaps, prior history, causation language, and missing records.
Turn a complete deposition transcript into a topic-based page-line summary with precise cites, verbatim excerpts, admissions, exhibits, and unanswered questions.
Turn an email and letter production into a dated who-knew-what-when timeline with thread lineage and Bates cites — knowledge milestones flagged.
Inventory every obligation, deadline, notice requirement, and condition precedent in the contract — who owes what, triggered by what, with section cites.
Draft the facts and damages narrative of a demand from the record itself — every sentence cite-backed, gaps flagged instead of papered over.
Flag every evasive, incomplete, or boilerplate-objection answer against what was actually asked — and walk away with your meet-and-confer list drafted.
Audit an expert's deposition against their report: new opinions, abandoned opinions, changed bases, and undisclosed reliance materials — the record a motion to exclude depends on.
Distill an IME or CME report: findings, concessions, the records the examiner says they reviewed — and the gap between that list and what actually exists.
Compare what the incident or police report recorded at the time against what the same actors said later under oath — every divergence classified and dual-cited.
Gather the record facts and cites that support each interrogatory answer — facts only, gaps flagged, so the attorney drafts from evidence instead of memory.
A neutral-tone summary of the record organized for a mediation statement: liability, damages, what's genuinely disputed, and what both sides already agree on.
A client-friendly status summary of the record at an eighth-grade reading level — jargon translated, honest about what's unresolved, nothing overpromised.
Align a witness's deposition against every prior statement, classify each conflict, and get a lock-in → confrontation cross sequence with dual cites.
Turn a set of withheld documents into a privilege log — date, author, recipients, type, and a non-waiving basis for each — with the doubtful calls flagged for review.
Index a document production end to end: document type, date, author, recipients, Bates range, and a one-line description — with the anomalies surfaced.
The standing-rules prompt: paste this once at the start of a chat session and every answer after it comes cited, sourced, and honest about gaps.
Draft Requests for Admission aimed at single facts the record already supports — one fact each, grouped by issue, plus authentication RFAs and the facts you still need.
Itemize the medical specials from the records and bills — provider, dates, treatment, billed, paid, and outstanding — totaled, with relatedness and missing bills flagged.
Turn the record into a numbered Statement of Undisputed Material Facts for summary judgment — each fact a single sentence tied to a cite, with the genuinely disputed ones pulled out.
Pull proposed deposition designations on your issues with page:line in/out points, verbatim anchors, and a colloquy-cleanup flag on every range.
One witness, every prior statement: a prep sheet of everything they've said, organized by topic and dated, with the soft spots flagged before the other side finds them.
Each worked example pairs one prompt with one practice lens, so you can see what changes for insurance defense, personal injury, criminal, or family work.