You are a deposition coach for plaintiff's personal injury counsel. Create a detailed Pre-Deposition Checklist for [CASE TYPE: auto accident/premises liability/medical malpractice]. The checklist should cover: 1. CASE FILE REVIEW — key documents, timeline, prior statements, admissions 2. WITNESS ANALYSIS — background, credibility vulnerabilities, bias, motive 3. DOCUMENT ORGANIZATION — exhibit binders, privilege logs, designations 4. DEPOSITION OUTLINE — key topic clusters, impeachment opportunities, cross-examination strategy 5. LOGISTICS — date/time confirmation, location, court reporter, videographer, tech setup 6. TEAM COORDINATION — witness prep, co-counsel roles, expert availability if needed 7. SELF-PREP — research opposing party facts, applicable case law, local rule reminders 8. EVIDENCE PRESERVATION — video backup, transcript review process, designated deposition designations Output: A single-page checklist in markdown, organized as boxes with checkmarks, grouped by phase (pre-deposition week, 48 hours before, day before, deposition morning). Make it immediately actionable—items should be specific to this case type, not generic.

Create a Deposition Day Checklist for [YOUR ROLE: deposing counsel/defending counsel/client representative]. Organize into these sections: BEFORE YOU LEAVE HOME (night before check): - Equipment and documents to pack - Tech backup (laptop, portable charger, external drives) - Personal items (water, snacks, phone chargers) ARRIVAL & SETUP (60 minutes early): - Venue verification (wrong building, parking, security) - Equipment check (video/audio test, internet, backup power) - Document layout (witness can see? exhibits visible?) - Court reporter coordination (numbering system, transcript delivery) - Witness management (if client: positioning, signaling rules) IMMEDIATELY BEFORE SWEARING IN: - Rule clarifications (off-the-record, time breaks, speaking objections) - Last-minute file review (key impeachment docs on top) - Stenographer confirmation (delivery timeline, format) DURING THE DEPOSITION: - Speaker notes (topics completed, time markers for video review) - Document management (clear exhibit handling, visual record) - Witness demeanor (breaks needed? witness deteriorating?) IMMEDIATELY AFTER: - Transcript delivery confirmation - Video backup verification - Exhibit and deposition copy collection - Client debrief (if present) Output: A single page, checkbox format, organized by time phase. Must be specific and non-redundant.

Create an Objection Quick Reference Card for deposition counsel (jurisdiction: [STATE]). Format as a two-column table with these columns: OBJECTION | EXACT LANGUAGE | WHEN TO USE | INSTRUCTIONS AFTER Cover these 12 objections: 1. Form of the question (vague, ambiguous, compound) 2. Lacks foundation 3. Assumes facts not in evidence 4. Calls for speculation 5. Calls for legal conclusion 6. Outside the scope of [Rule 30(b)(6) / party deposition] 7. Harassing/oppressive/burdensome 8. Privileged (attorney-client, work product, physician-patient) 9. Calls for information protected by [statute] 10. Incomplete hypothetical / inconsistent facts 11. Asked and answered 12. Argumentative / mischaracterizes prior testimony For each: give exact objection phrasing, one scenario when it applies, and whether to instruct witness not to answer. Include a footer note: "Deposing counsel: Objections must be stated concisely. Do NOT give speeches or explain legal bases—opposing counsel will move to strike." Output: Single-page reference card, 12pt font, grid format, suitable for quick glance during deposition.

Create a Federal Rules Cheat Sheet covering deposition and discovery rules on ONE page. Format: RULE | PLAIN ENGLISH SUMMARY | CRITICAL PROVISION | PRACTICE NOTE Cover: - FRCP 26(b)(1) — Scope of discovery (relevance, proportionality) - FRCP 26(b)(3) — Work product protection - FRCP 26(c) — Protective orders - FRCP 26(f) — Meet and confer, discovery plan - FRCP 30(a) — Notice and timing of depositions - FRCP 30(b) — Depositions by written questions - FRCP 30(b)(6) — Party deposition (organization's designee) - FRCP 30(c) — Rules during deposition (record format, objections, court reporter, oath) - FRCP 30(d) — Limits on depositions (7 hours per day, one deposition per party, timing restrictions) - FRCP 33 — Interrogatories (written questions, number limits, timing) - FRCP 34 — Requests for production (documents, scope, timing) For each rule: one-sentence plain English version, the specific subsection number, one critical practice tip. Keep it scannable. Include a footer with: "Local rules vary by court—always check your specific district's standing orders before a deposition." Output: Single page, 10-11pt font, suitable for quick reference in the courtroom or during deposition.

Create a Texas Rules of Civil Procedure Cheat Sheet for depositions. Format as a reference card covering: RULE | TEXAS LANGUAGE | KEY DIFFERENCE FROM FEDERAL | PRACTICE TIP Cover: - TRCP 199.1 — Scope of discovery - TRCP 199.2 — Protective orders - TRCP 200.1 — Depositions in general - TRCP 200.2 — Notice of deposition - TRCP 200.3 — Deponent's duties and rights - TRCP 200.4 — Depositions by written questions - TRCP 200.5 — Recording and transcription - TRCP 205.1 — Interrogatories (number limits, spacing) - TRCP 192.3 — Requests for production - TRCP 193 — Withholding discovery (privilege, work product, trial preparation materials) For each rule: cite the specific TRCP section, key language, explain how it differs from FRCP (if significant), and give one practice tip specific to Texas practice. Include a note about Texas-specific rules (e.g., deponent control, mandatory disclosure, presuit notice of deposition). Output: Single-page card, 10-11pt font, organized in table format. Include a header: "Texas Deposition & Discovery Rules Quick Reference."

Create a comprehensive Expert Deposition Outline Template. Organize into phases with sample questions and probe areas: I. CREDENTIALS & QUALIFICATIONS A. Education and training B. Professional licenses and certifications C. Current employment and roles D. Prior expert testimony (frequency, subject matter, outcomes) E. Compensation arrangements for this engagement Sample probe: "How much have you been paid for your work in this case to date?" II. CASE INVOLVEMENT A. How retained (who contacted you? when?) B. Scope of engagement C. Documents reviewed D. People interviewed E. Testing or physical examination performed Sample probe: "Did opposing counsel or my client direct your methodology?" III. METHODOLOGY & BASIS A. Standard of care / industry standards applied B. Specific methodology used in this case C. Alternative methodologies considered and rejected D. Assumptions made E. Data, calculations, and analysis Sample probe: "Is your methodology consistent with how other experts in your field would approach this issue?" IV. OPINIONS & CONCLUSIONS A. Final opinions stated B. Bases for each opinion C. Assumptions supporting each opinion D. Reliability of each opinion (degree of certainty) Sample probe: "What is the scientific or professional support for that opinion?" V. BIAS & FINANCIAL INTEREST A. Prior relationships with parties or counsel B. Percentage of income from litigation C. Repeat engagement with same firm/party D. Any statements about predisposition to one side Sample probe: "Of your expert work, what percentage comes from defense vs. plaintiff counsel?" VI. ALTERNATIVE THEORIES & WEAKNESSES A. Alternative explanations for the facts B. Literature or studies contradicting expert's opinion C. Treatises and standards that support alternative view D. Limitations of expert's analysis Sample probe: "Are you aware of [leading treatise/article] that reaches a different conclusion?" VII. REPORT & EXHIBITS A. Detailed review of expert report B. Exhibits attached to report C. Any updates or changes since report D. Consistency with prior statements Sample probe: "Has anything changed in your opinions since you prepared your report?" VIII. DEPOSITION TRANSCRIPT REVIEW (end of deposition) A. Ensure expert understands court reporter will produce transcript B. Expert will have opportunity to make corrections C. Corrections should be noted and explained Output: Provide as a detailed outline with bracketed fill-in areas [CASE CONTEXT], [EXPERT'S FIELD], [KEY OPINION]. Make it reusable across case types.

Create a comprehensive Fact Witness Deposition Outline Template. Organize into phases: I. BACKGROUND & CREDIBILITY A. Full legal name, current address B. Employment (current and prior 5 years) C. Education D. Prior litigation involvement E. Any felony convictions Sample probe: "Have you ever been convicted of a felony?" II. RELATIONSHIP TO PARTIES A. Personal relationship to plaintiff / defendant B. Business relationship C. Any financial interest in the outcome D. Communications since incident Sample probe: "Have you discussed this case with anyone? What did you discuss?" III. PERCEPTION & MEMORY A. Presence at key events (when, where, for how long) B. Sensory perception (what could witness see, hear, smell) C. Environmental conditions (lighting, noise, obstruction of view) D. Witness's own condition (sober? injured? distracted?) E. Basis for recollection (how does witness remember? notes? photos?) Sample probe: "How are you able to remember those details from [DATE]?" IV. TIMELINE OF EVENTS A. Detailed chronological account of relevant events B. Duration and sequence of key moments C. Any gaps or uncertainties in recollection D. Basis for timing (clock? watch? estimation?) Sample probe: "How certain are you about the timing of those events?" V. PRIOR STATEMENTS & DOCUMENTS A. Police reports or statements to law enforcement B. Written statements to insurance or parties C. Emails, text messages, social media posts about the incident D. Photographs or videos taken by witness E. Inconsistencies between prior statement and deposition testimony Sample probe: "In your statement to [investigator], you said [quote]. What do you mean by that?" VI. DOCUMENTS & PHYSICAL EVIDENCE A. Ability to identify documents witness created or received B. Accuracy of documents C. Any alterations or corrections to documents Sample probe: "Is this your [signature/handwriting]? What does this document mean?" VII. IMPEACHMENT OPPORTUNITIES A. Use of prior statements (inconsistent statement, omissions) B. Bias or interest in outcome C. Sensory limitations or unreliability D. Scientific or objective evidence contradicting testimony Sample probe: "Your statement says [A], but today you testified [B]. How do you explain that?" VIII. EXPERT OR SPECULATIVE OPINIONS A. Any conclusions beyond witness's personal knowledge B. Opinions about causation, fault, or liability C. Basis for any such opinions Sample probe: "Other than what you personally saw, why do you believe that [conclusion]?" Output: Provide as reusable template with bracketed fill-in areas [WITNESS NAME], [INCIDENT DATE], [KEY TOPIC]. Suitable for fact witnesses across all case types.

Create a 30(b)(6) Topic Checklist for [CASE TYPE: auto accident/product liability/premises liability/employment discrimination]. Organize by topic cluster: I. ORGANIZATIONAL STRUCTURE & AUTHORITY A. Decision-making authority (who approves what?) B. Reporting structure and chain of command C. Policies and procedures governing [KEY ISSUE] D. Training and compliance programs II. POLICIES & PROCEDURES A. Written policies (safety, maintenance, hiring, etc.) B. Deviations from written policy C. How policies are communicated to employees D. Who is responsible for policy compliance III. INCIDENT RESPONSE & INVESTIGATION A. How the organization became aware of the incident B. Initial response (reporting, preservation, notification) C. Internal investigation (who conducted it? what was found? any report?) D. Preservation of evidence (physical items, documents, digital) IV. RECORDS & DOCUMENTATION A. Availability of relevant records (maintenance logs, incident reports, inspection records) B. Retention policies (how long records are kept) C. How records are organized and retrieved D. Destruction or deletion of any records related to incident V. PRIOR SIMILAR INCIDENTS A. Prior incidents or complaints related to [KEY ISSUE] B. How prior incidents were addressed C. Any pattern of issues VI. COMMUNICATIONS A. Internal communications about the incident B. External communications (insurance, counsel, regulatory bodies) C. Any admissions or statements made by the organization VII. FINANCIAL & OPERATIONAL IMPACT A. Costs associated with the incident B. Insurance coverage and claims C. Any operational changes made after the incident VIII. COMPLIANCE & REGULATORY A. Relevant regulatory standards or requirements B. Regulatory inspections or violations C. Corrective actions taken Output: Single-page checklist organized by topic. For each topic, list 2-3 critical sub-questions. Ensure topics are specific to [CASE TYPE] provided—no generic topics. Include note: "30(b)(6) designee should be prepared to testify about organizational knowledge, not personal opinion. Use foundation questions to establish designee's authority to speak for the organization."

Create an Impeachment Techniques Quick Reference with these sections: 1. PRIOR INCONSISTENT STATEMENT Step 1: Establish current testimony (lock it in) Step 2: Reference prior statement (time, place, context) Step 3: Read or quote the prior statement Step 4: Ask if witness has any explanation Step 5: Argument (leave for closing) Example Q: "Just to be clear, you're testifying today that X happened. Correct? But in your deposition on [DATE], you testified that Y happened. How do you explain that difference?" 2. BIAS & INTEREST Step 1: Establish witness's relationship to party Step 2: Establish financial or other interest in outcome Step 3: Establish witness has motive to shade testimony Step 4: Explore any prior bias or predisposition Example Q: "You work for the defendant, correct? And if the defendant loses this case, that could affect your job, couldn't it?" 3. SENSORY OR MEMORY LIMITATIONS Step 1: Establish conditions (lighting, distance, obstruction, noise) Step 2: Establish witness's own condition (injury, intoxication, distraction) Step 3: Establish time lapse since incident Step 4: Explore any factors that would affect perception or recollection Example Q: "You said this happened very quickly. How long are we talking—seconds? Less than a second? And you were [focused on Y], so you weren't expecting to see what happened, correct?" 4. CONTRADICTION VIA DOCUMENT Step 1: Establish foundation (what is the document? who prepared it? when?) Step 2: Establish authenticity (is this your signature/handwriting?) Step 3: Establish the witness's knowledge (did you prepare this? were you present when it was prepared?) Step 4: Quote or read the contradictory language Step 5: Ask witness to explain Example Q: "This incident report, prepared on [DATE] by [PERSON], states 'X happened.' That contradicts your testimony that Y happened. What's your explanation?" 5. CHARACTER FOR TRUTHFULNESS (Extrinsic Evidence) Foundation: Establish witness has reputation in their community for untruthfulness or dishonesty Step 1: Ask witness if they're aware of their reputation Step 2: If witness denies or equivocates, you can offer extrinsic evidence Caution: Limited in scope; cannot attack on collateral matters Example Q: "Are you aware that people in [COMMUNITY] know you to be dishonest?" 6. CONTRADICTION VIA OBJECTIVE EVIDENCE Step 1: Establish what objective evidence shows (speed, distance, timing, etc.) Step 2: Establish the evidence is reliable and accurate Step 3: Ask witness how they explain the contradiction Step 4: Argue in closing Example Q: "The accident reconstruction expert calculated that the vehicle was traveling at least 45 mph at the time of impact. Your testimony was that the driver was going about 20 mph. How do you account for that difference?" 7. PRIOR CONVICTION (Character for Truthfulness) Rule: If conviction is a felony, or involves dishonesty, use to impeach Step 1: Ask witness if they've been convicted of a crime Step 2: If yes, ask nature of conviction and when Step 3: (Felony involving dishonesty is most powerful) Caution: Limit scope to conviction itself; don't argue the original facts Output: Single-page card with 7 techniques, each with numbered steps and a sample Q. Include a footer: "Impeachment is most effective when you have the document in hand or the evidence locked in. Never ask a question you don't know the answer to."

Create a Common Deposition Traps reference covering 10 mistakes to avoid: 1. FAILING TO ESTABLISH FOUNDATION BEFORE USING A DOCUMENT The Trap: Showing a document without first establishing what it is, who made it, when, and in what context. Opposing counsel objects and it becomes unclear on the record. Prevention: Always ask foundational questions first. "Do you recognize this document? When was it created? Who created it? Have you seen this before? Did you prepare this?" 2. ASKING QUESTIONS YOU DON'T KNOW THE ANSWER TO The Trap: You assume a witness will give testimony favorable to your position, but they don't. You're now stuck with their answer. Prevention: Review all witness statements, documents, and deposition outlines before you begin. Know the likely answer. If you don't, don't ask. 3. ARGUING WITH THE WITNESS DURING DEPOSITION The Trap: Getting emotional or argumentative causes the witness to shut down or become defensive. Opposing counsel objects and notes it for the record. You damage your credibility. Prevention: Remain calm and professional. Your job is to lock in testimony, not to convince the witness. Save argument for closing. 4. FAILING TO PRESERVE IMPEACHMENT EVIDENCE The Trap: You spot an inconsistency during deposition but don't lock it in with specific questions. Later, you can't use it because the record doesn't clearly show the inconsistency. Prevention: When you spot an inconsistency, ask clear, specific follow-up questions to lock in both the current testimony AND reference the prior statement. "So you're saying X happened? Not Y?" 5. NOT DESIGNATING EXHIBITS CLEARLY The Trap: You show 20 documents, the court reporter doesn't number them clearly, and later you can't figure out which exhibit was which in the transcript. Prevention: Slow down. Hand each document to the court reporter and ask them to mark it. Use exhibit numbers or letters. Say the exhibit number on the record multiple times. "I'm showing you Exhibit 3. Can you identify this?" 6. ALLOWING VAGUE OR NONRESPONSIVE ANSWERS The Trap: Witness gives a long, rambling answer that doesn't address your question. You move on. Later, the answer is ambiguous and you can't use it effectively. Prevention: Interrupt politely. "That doesn't answer my question. Let me rephrase. Did X happen or didn't it?" Get yes/no answers when possible. 7. OVER-OBJECTING (OR UNDER-OBJECTING) The Trap (Over): If you object to every question, it looks defensive and makes the record messy. (Under): If you fail to object to improper questions, you waive your objection. Prevention: Object only when necessary. Know the deposition rules of your jurisdiction. Confer with opposing counsel on obvious missteps. Save serious objections for trial. 8. FAILING TO FOLLOW UP ON HELPFUL TESTIMONY The Trap: A witness gives you great testimony, but you don't ask follow-up questions to lock it in. Opposing counsel later tries to water it down. Prevention: When you get helpful testimony, ask confirming questions. "So you're certain about that? And there's no doubt in your mind? Could you explain why you're so certain?" 9. NOT MANAGING YOUR CLIENT OR CO-COUNSEL The Trap: Your client or co-counsel is making faces, shaking their head, or making side comments. Opposing counsel sees it. The witness sees it. It undermines your case and confuses the record. Prevention: Brief your team before the deposition. Position them where they can listen but not react visibly. Have a signal if something goes wrong. Control the room. 10. FAILING TO REVIEW THE DEPOSITION TRANSCRIPT The Trap: You don't review the transcript before trial. You discover errors, ambiguities, or problems too late. The witness is unavailable for a second deposition. Prevention: Within 1 week, read through the transcript. Flag any changes the witness wants to make. Note any unclear language. Consult with client and co-counsel about strategy implications. Output: Provide as a single-page checklist. For each trap, use bold for the trap title, then one-sentence prevention tip. Include a footer: "The best defense against depositions traps is preparation. Know your facts, know your documents, and know your law before you walk in the room."

Create a Client Deposition Preparation Handout for [CLIENT ROLE: plaintiff/defendant]. Format as a 2-3 page document clients can take home and read. Include these sections: WHAT IS A DEPOSITION? - Plain-English explanation: Question-and-answer under oath, recorded by court reporter - Who will be present (opposing counsel, your attorney, court reporter, possible videographer) - Where it will be held - How long it typically takes BEFORE THE DEPOSITION - Schedule a prep meeting with your attorney [DATE/TIME] - Bring all documents related to the incident - Review any statements you've made before - Get a good night's sleep the night before - Wear business casual clothing (no jeans, no logos) - Arrive 15 minutes early - Use the restroom before starting DURING THE DEPOSITION: THE DOS - Listen carefully to each question before answering - Answer only the question asked; don't volunteer information - Take your time; don't rush to answer - Say "I don't know" or "I don't remember" if true - Ask for clarification if you don't understand the question - Tell the truth, even if the answer hurts your case - If your attorney objects, listen to their instruction and follow it - Remain calm and professional; don't get emotional - If you need a break, ask for one DURING THE DEPOSITION: THE DON'Ts - Don't guess or speculate - Don't argue with opposing counsel - Don't make jokes or try to be funny - Don't look at your attorney for answers (it looks coached) - Don't talk over opposing counsel or interrupt - Don't exaggerate or minimize facts - Don't say "I think" or "I believe"—say "I know" or "I remember" only if true - Don't volunteer information not asked for - Don't get defensive if opposing counsel is hostile (that's their job) SAMPLE QUESTIONS & ANSWERS Provide 3-4 real-world examples showing: - Good answer: Direct, brief, truthful - Bad answer: Rambling, argumentative, evasive AFTER THE DEPOSITION - Your attorney will review the transcript - You may be asked to make minor corrections - Keep this deposition confidential (don't discuss with witnesses) Output: Format as a downloadable PDF-ready document. Use clear headings, bullet points, and easy-to-scan layout. Include a footer with attorney contact information and "Don't hesitate to call if you have questions before your deposition."

Create a Post-Deposition Action Items Checklist. Organize by timeline and task: IMMEDIATELY AFTER (same day): □ Verify transcript delivery timeline with court reporter (when will draft transcript be available?) □ Collect all exhibits and originals (ensure nothing is left at deposition location) □ Confirm video backup (if video was used, confirm backup copy and storage location) □ Debrief with client (if present) — key takeaways, what went well, concerns □ Debrief with co-counsel — impressions, strategy implications, follow-up needed □ Document any technical or procedural issues for the record □ Photograph or scan any exhibits for future reference WITHIN 3 DAYS: □ Review draft transcript (use search function to locate key topics) □ Flag any errors, inaudible portions, or unclear passages □ Flag any changes the deponent wants to make (per their correction rights) □ Prepare errata sheet if corrections are needed □ Confirm transcript will be signed under oath (jurisdictional requirement) □ Confirm deponent's 30-day window to make corrections and submit WITHIN 1 WEEK: □ Complete full transcript review — identify: - Helpful testimony to lock in for trial - Inconsistencies with prior statements or documents - Weaknesses or evasions needing follow-up - Areas requiring additional discovery □ Prepare trial outline or summary (if trial is approaching) □ Prepare designated deposition designations (if required by local rule or trial order) □ Update case timeline or chronology with new information □ Send corrected transcript to opposing counsel (if corrections made) □ Brief client on implications of testimony for case strategy WITHIN 2 WEEKS: □ Analyze impact on case evaluation (did testimony strengthen or weaken your case?) □ Identify any follow-up depositions needed (same witness? new witnesses? expert rebuttal?) □ Prepare notice of follow-up deposition (if needed) □ Update attorney work product (strategy memo, case evaluation, risk assessment) □ Determine if new discovery is necessary based on deposition testimony □ Schedule meeting with client to discuss settlement value or trial strategy ONGOING: □ Organize exhibits and deposition transcript in case file/case management system □ Cross-reference deposition testimony with other key documents (maintain index) □ Flag deposition testimony for trial exhibits and cross-examination outlines □ Monitor for any sanctions or procedural violations by opposing counsel Output: Single-page checklist with clear boxes and time phases. Include a footer: "Don't let deposition transcripts sit unreviewed. The sooner you review and analyze, the sooner you'll spot follow-up discovery or strategy adjustments needed."

Create a Settlement Evaluation Worksheet for [CASE TYPE]. Format as a structured analysis document with these sections: I. CASE IDENTIFICATION - Case name and court - Client role (plaintiff/defendant) - Opposing parties - Insurance coverage (if known) - Evaluation date II. LIABILITY ANALYSIS Liability Strength (1-10 scale, 10=strongest): - Strength of your liability position: ____/10 - Opposing party's liability position: ____/10 - Key liability witnesses: a. Your strongest witness: ________________ b. Opposing party's strongest witness: ________________ c. Vulnerable areas in your case: ________________ - Probability of liability finding at trial: ____% - Counterclaims or comparative fault: ________________ III. DAMAGES ANALYSIS Medical/Economic Damages: - Medical expenses (documented): $________ - Lost wages (documented): $________ - Future medical treatment (estimated): $________ - Other economic damages: $________ - Total economic damages: $________ Non-Economic Damages (pain, suffering, disfigurement, loss of enjoyment): - Severity of injury (1-10 scale): ____/10 - Duration of recovery/permanency: ________________ - Impact on daily life/work capacity: ________________ - Credibility of damages testimony: Strong / Moderate / Weak - Comparable awards in similar cases: $________ - Estimated non-economic damages: $________ TOTAL DAMAGES (economic + non-economic): $________ IV. RISK ANALYSIS Defense Risk Factors: - Likelihood of losing entirely: ____% (Risk of $0 verdict) - Likelihood of verdict below economic damages: ____% (Risk of ________) - Likelihood of full damages verdict: ____% (Best case: $________) Plaintiff Risk Factors (if you are defense): - Likelihood of summary judgment in your favor: ____% (Best case: dismiss) - Likelihood of favorable settlement before trial: ____% - Cost of defending through trial: $________ V. CASE VALUE SCENARIOS Best Case Scenario: - Liability: 100% liable - Damages: $________ - Trial/Trial Value: $________ Worst Case Scenario: - Liability: Lose entirely (0% liable) OR Comparative fault reduces recovery - Damages: $________ - Trial/Trial Value: $________ Expected Value (probability-weighted): - Probability of success: ____% x Likely recovery $ = Expected value - Expected Value: $________ VI. SETTLEMENT OFFER EVALUATION Offer Received: $________ Offer as % of Expected Value: _____% Analysis: - Is offer above, at, or below expected value? - What is your litigation cost to trial if you reject this offer? - Will trial delay benefit or harm your case? - Client's preference (settlement vs. trial)? VII. CLIENT FACTORS - Client's financial situation (can they afford to wait for trial?) - Client's emotional/psychological tolerance for continued litigation - Client's goals (money? vindication? trial precedent?) - Client's risk tolerance (willing to gamble?) VIII. RECOMMENDATION Based on expected value, litigation risk, costs, and client factors: Settle at $________ or higher Reject offers below $________ Justify your recommendation in 2-3 sentences Output: Provide as a detailed worksheet with fill-in areas and calculation fields. Include a footer: "Settlement evaluation should be revisited after major depositions or discovery. Your case assessment will evolve as facts develop."

Create a Discovery Response Deadline Tracker (automated calculator). Format as an interactive spreadsheet template or form: INPUT FIELDS: □ Request Type (Interrogatory / Request for Production / Deposition Notice / Request for Admission) □ Date of Request / Service: ____________________ □ Jurisdiction (Federal FRCP / Texas TRCP / [OTHER STATE]): ____________________ □ Agreement to Extend? (Yes/No) + Extension Duration: ____________________ □ Special Circumstances (Holiday? Excuse for delay?): ____________________ CALCULATED DEADLINES: Response Due Date: ____________________ (Formula: 30 days from request date, or as modified by court order / agreement) Objection Due Date (if asserting privilege or work product): ____________________ (Formula: Same as response date, but must serve preliminary objections in writing) Supplemental Response Deadline (if circumstances change): ____________________ (Formula: Before trial, as required by FRCP 26(e) or TRCP 194.1) Production Location (if applicable): ☐ Email: ____________________ ☐ In-person inspection: Date/Time: ____________________ ☐ Electronic format: ☐ Native ☐ PDF ☐ TIFF COMPLIANCE CHECKLIST: □ Response prepared (all required documents/answers) □ Objections reviewed (privilege, work product, scope) □ Signature required (attorney + client if appropriate) □ Proof of service prepared (how will you serve? email? overnight?) □ Copy retained for your file □ Calendar reminder set for supplemental disclosure (30 days before trial) EXTENSIONS / MODIFICATIONS: □ Extension agreed to (in writing)? Date: ____________________ □ Modified response deadline: ____________________ □ Modified production format: ____________________ RISK MANAGEMENT: ☐ Are you missing any documents in your response? Flag for follow-up ☐ Are any objections challengeable? Note for strategy ☐ Will opposing counsel likely move to compel? Prepare defenses now Output: Provide as a downloadable spreadsheet-style form or as a reference card showing calculation formulas for FRCP and TRCP. Include a footer: "Deadline extensions must be in writing and agreed to before the deadline. Do not miss deadlines—missing discovery deadlines can result in sanctions, waiver of objections, or summary judgment against you."

Create a Deposition Cost Estimator. Format as a checklist with line-item calculations: DEPOSITION DETAILS: - Deponent name: ________________ - Deposition date: ________________ - Location: ________________ - Expected duration: _____ hours - Number of attendees (your team): _____ - Video deposition? (Yes/No) - Exhibit binders needed? (Yes/No, if yes, quantity: ____) COURT REPORTER COSTS: - Court reporter hourly rate: $____/hour - Estimated deposition hours: _____ × $____ = $________ - Court reporter setup fee (if any): $________ - Real-time transcript (if added): $________ - Rough draft transcript: $________ - Final transcript (with errata): $________ - Expedited delivery fee (if applicable): $________ SUBTOTAL: $________ VIDEOGRAPHER COSTS (if applicable): - Videographer rate: $____/hour - Estimated hours: _____ × $____ = $________ - Video setup/breakdown fee: $________ - Video backup/storage fee: $________ - Video editing (if needed): $________ SUBTOTAL: $________ LOCATION & SETUP COSTS: - Deposition room rental: $________ - Parking (your team): $________ - Stenography equipment rental (if not included with reporter): $________ SUBTOTAL: $________ TRAVEL COSTS (if deposition is out of town): - Airfare (# of attendees): $________ - Hotel (# of nights × # of attendees): $________ - Meals/ground transportation: $________ - Car rental (if applicable): $________ SUBTOTAL: $________ DOCUMENT PREPARATION: - Exhibit binder preparation (copies, binding, tabs): $________ - Exhibit labeling/scanning: $________ - Privilege log preparation (if any privilege asserted): $________ SUBTOTAL: $________ EXPERT WITNESS COSTS (if expert attending/testifying): - Expert preparation time (consultation before deposition): $________ - Expert deposition attendance fee: $________ - Travel costs for expert: $________ SUBTOTAL: $________ MISCELLANEOUS: - Office supplies (notepads, pens, folders): $________ - Deposition notice preparation/service: $________ - Post-deposition transcript storage/management: $________ SUBTOTAL: $________ GRAND TOTAL DEPOSITION COST: $________ COST BREAKDOWN BY CATEGORY: - Court reporter & transcript: ____% of total - Video & documentation: ____% of total - Travel & location: ____% of total - Expert fees (if applicable): ____% of total - Other: ____% of total BUDGET COMPARISON: - Estimated budget approved by client: $________ - Actual estimated cost: $________ - Variance: $________ (over/under) OUTPUT: Provide as a fillable PDF or spreadsheet. Include notes like: "Court reporter rates vary by region. Check with your local court reporter for current pricing." "If multiple parties are deposing the same witness, costs may be shared (negotiate with opposing counsel)." "Factor in transcript corrections and potential follow-up depositions when budgeting."

Create an AI Prompt Cheat Sheet — Top 10 Most-Used Prompts from the DIB Field Manual. Format as a single-page quick reference: HEADER: "AI Prompt Cheat Sheet — DIB Field Manual Edition" Subtitle: "Top 10 Most-Used Prompts for Litigators" COLUMNS: PROMPT # | USE CASE | ONE-LINE DESCRIPTION | WHEN TO USE 1. Deposition Question Generator Use: Create tough questioning sequences for any witness type Description: Generate 10-15 high-impact deposition questions organized by topic When to Use: Before any significant deposition, focus your questioning strategy 2. Chronology & Timeline Builder Use: Create detailed incident timelines from scattered facts Description: Turn case documents into a visual chronology with key events and actors When to Use: Early in case, before expert retention, for settlement negotiations 3. Inconsistency & Contradiction Analyzer Use: Spot gaps and contradictions in witness testimony or documents Description: Compare multiple statements or versions and flag discrepancies When to Use: During deposition prep, after reviewing opposing party documents 4. Objection Language Generator Use: Get exact, proper objection language for any scenario Description: Provide the objection, when to use it, and what to say after When to Use: Before depositions, during trial prep, to avoid speaking objections 5. Deposition Summary & Key Extract Use: Quickly extract key testimony from multi-hour depositions Description: Pull out the 5-10 most important quotes and organize by topic When to Use: After deposition transcript received, need quick summary for client 6. Damages Calculation & Projection Use: Organize and project damages (medical, lost wages, future damages) Description: Create structured damages summary with present/future value calculations When to Use: Before settlement discussions, to evaluate reasonableness of claims 7. Expert Report Critique & Vulnerability Analysis Use: Identify weaknesses in opposing expert's methodology or opinion Description: Analyze expert report, flag methodological flaws, suggest cross-examination angles When to Use: After receiving opposing expert report, to plan expert deposition 8. Settlement Value Calculator Use: Estimate fair settlement range based on case facts and comparable cases Description: Structured analysis of liability, damages, risk, and settlement range When to Use: Before settlement negotiations, after key depositions 9. Discovery Objection & Privilege Tracker Use: Organize and defend discovery objections (privilege, work product, burden) Description: Create privilege log with proper descriptions, withholding justifications When to Use: When asserting privilege in discovery response, before motion to compel 10. Trial Outline & Witness Order Optimizer Use: Create trial outline organizing witnesses, exhibits, and legal arguments Description: Build witness sequence by impact, create cross-examination outlines When to Use: After discovery close, during trial prep phase BONUS PROMPTS (Worth Knowing): - Client Settlement Briefing (create simple settlement offer analysis for client) - Impeachment Opportunity Mapper (identify all impeachment angles from documents) - Comparative Case Law Finder (research similar cases for damages benchmarking) HOW TO USE THIS CHEAT SHEET: 1. Identify your immediate task (deposition prep? discovery response? trial planning?) 2. Find the matching prompt from the 10 above 3. Go to the DIB Field Manual chapter indicated 4. Copy the full prompt text into Claude 5. Add your case-specific details (witness name, case type, etc.) 6. Generate your result TIPS FOR BEST RESULTS: - Be specific about case type, jurisdiction, and your role (deposing vs. defending counsel) - Provide context: key dates, parties, facts the prompt needs to work with - Request specific format (checklist, table, memo, Q&A) if you have a preference - Ask for follow-up refinements if the first output isn't quite right Output: Single-page quick reference with 10 prompts organized by use case. Include a footer: "Use these prompts to jumpstart your case work. Each prompt is customizable—adjust for your case and get court-ready work product in minutes, not hours."