Pull facts, evidence references, and legal elements from a deposition into a structured catalog.
When to use it
Use when you need a comprehensive fact inventory from a deposition — separating undisputed facts from disputed, fact from opinion, and personal knowledge from hearsay. Particularly useful when drafting motions or organizing trial exhibits.
The prompt
Copy the prompt below, paste into ChatGPT, Claude, or your firm's preferred LLM, then paste your transcript where the placeholder indicates.
Perform comprehensive fact extraction from this deposition transcript, organizing all factual assertions, evidence references, and legal elements for case preparation:
## Factual Assertions Catalog
**Undisputed Facts Established:**
For each clear factual assertion:
- **Fact:** [Specific factual claim]
- **Source:** [Page/line reference]
- **Context:** [Circumstances of this statement]
- **Significance:** [Why this fact matters legally]
- **Corroboration Needed:** [How to verify this fact]
**Disputed or Contradicted Facts:**
- **Claimed Fact:** [What witness claims]
- **Dispute Nature:** [Why this is questionable]
- **Alternative Versions:** [Other accounts of same fact]
- **Resolution Method:** [How to determine truth]
**Opinion vs. Fact Separation:**
- **Statement:** [Witness statement]
- **Classification:** [Fact/Opinion/Mixed]
- **Basis for Opinion:** [What supports witness opinion]
- **Admissibility Issues:** [Potential evidence problems]
## Evidence References
**Documents Mentioned:**
- **Document Type:** [Contract, email, report, etc.]
- **Description:** [What witness said about document]
- **Relevance:** [How this relates to case issues]
- **Availability:** [Whether produced, location, access]
- **Authentication Issues:** [Problems with proving authenticity]
**Physical Evidence References:**
- **Item:** [Object, location, condition described]
- **Witness Knowledge:** [How witness knows about this]
- **Current Status:** [Where evidence is now]
- **Chain of Custody:** [Who has handled this evidence]
**Electronic Evidence:**
- **Type:** [Emails, texts, digital files, recordings]
- **Access Information:** [How witness accessed this]
- **Storage Details:** [Where this information is kept]
## Legal Elements Analysis
**Cause of Action Elements:** [Adjust based on your case type]
- **Element 1:** [Legal requirement]
- **Supporting Testimony:** [How witness testimony supports]
- **Page References:** [Specific locations]
- **Strength Assessment:** [How strong this support is]
- **Additional Proof Needed:** [What else is required]
**Damages Evidence:**
- **Economic Damages:** [Financial losses mentioned]
- **Amount:** [Specific figures given]
- **Calculation Method:** [How witness determined amount]
- **Supporting Documentation:** [Records that back this up]
- **Non-Economic Damages:** [Pain, suffering, intangible losses]
- **Description:** [How witness described impact]
- **Duration:** [How long effects lasted/will last]
## Witness Knowledge
**Personal Knowledge Areas:**
- **Direct Observation:** [What witness personally saw/heard]
- **Participation:** [Events witness was involved in]
- **Professional Expertise:** [Areas of claimed expertise]
**Hearsay and Secondhand Information:**
- **Source:** [Who told witness this information]
- **Context:** [When and why this was communicated]
- **Reliability Factors:** [Reasons to trust or doubt this information]
- **Admissibility Analysis:** [Whether this can be used at trial]
**Knowledge Limitations:**
- **Admitted Ignorance:** [What witness doesn't know]
- **Assumptions:** [What witness is guessing about]
- **Memory Problems:** [Areas of unclear or missing memory]
## Strategic Fact Analysis
**Facts Supporting Your Case** (with legal significance, strength, and reinforcement strategy)
**Facts Favoring Opposition** (with damage assessment, challenge strategy, mitigation options)
**Neutral Facts** (with development strategy)
Please maintain exact quote accuracy and provide specific page/line references for all citations.
Deposition transcript:
[PASTE YOUR TRANSCRIPT HERE]
How to use it well
Use the output to populate motion practice — supporting fact citations for summary judgment, motions in limine, and trial briefs.
The opinion-vs-fact separation is particularly valuable for evidentiary objections; flag inadmissible opinion testimony before trial.
Cross-reference the "Hearsay and Secondhand Information" section against your jurisdiction's hearsay exceptions before relying on any of it.
Run on multiple depositions in the same case, then merge outputs into a master fact spreadsheet keyed to legal elements.
Expected output
A structured fact catalog separating undisputed/disputed facts, opinion from fact, personal knowledge from hearsay — keyed to legal elements and damages evidence with page/line citations.
Yes. The Opinion vs. Fact Separation section classifies each statement as Fact, Opinion, or Mixed, with the basis for any opinion and admissibility flags. Useful for evidentiary objections and motions in limine.
Will it flag hearsay and admissibility issues?
Yes. The Hearsay and Secondhand Information section identifies the source, context, and reliability factors for hearsay testimony, and includes an admissibility analysis. Cross-reference against your jurisdiction's hearsay exceptions before relying on any of it.
Can it map facts to specific legal elements?
Yes — but customize the "Cause of Action Elements" placeholder for your specific cause of action. The prompt produces a default structure assuming general civil litigation; adapt the element list for negligence, breach of contract, employment, or whatever cause of action your case involves.
