Use case: Prepare for a deposition

You can use Gemini Enterprise to build a witness's documentary footprint from the case file and turn it into an outline where every line of questioning is tied to an exhibit.

Example prompt

In the chat box, enter a prompt such as the following:

You are a litigation associate preparing to depose the opposing party's
operations manager. Attached are the complaint, the answer, the parties'
agreement, the produced email set, and the transcript of the plant supervisor's
deposition.

Build a preparation packet:

1. **Witness footprint.** Every document in the attached record that this
witness authored, received, or is named in. Give the date, the document, the
Bates or exhibit number as it appears in the file, and one line on why it
matters. Order by date.

2. **Contradictions.** Any place this witness's documents conflict with the
plant supervisor's testimony, with the other party's pleadings, or with each
other. Quote both sides verbatim and cite each.

3. **Outline by topic.** For each topic, give the fact you are trying to
establish, the document you would use to establish it, and three to five
questions building to it. Every question must be answerable from a document in
the attached record.

4. **Anticipated problems.** Areas where the record is favorable to the witness,
and what they are likely to say.

5. **Not in the record.** Facts the pleadings assume that no attached document
supports. These are the questions where you have no exhibit to fall back on.

Rules:
- Use only the attached documents. Do not invent exhibit numbers, Bates numbers,
  dates, names, or quotes.
- Quote verbatim when you say a document says something, and cite it.
- If you cannot support a line of questioning from the record, put it under "Not
  in the record" rather than writing the question as though you can.
- Use bracketed placeholders such as [DATE NOT IN RECORD] rather than filling
  in a plausible value.

Example output

In response to this prompt, Gemini Enterprise produces output similar to the following:

Witness footprint

Date Document Cite Why it matters
Mar 4 Email, witness to plant supervisor CYM-000412 Directs a change to the inspection interval three weeks before the failure
Mar 19 Weekly operations report, authored by witness CYM-000871 Reports "no open maintenance items" for the affected line
Apr 2 Email chain, witness copied CYM-001033 Supervisor raises a vibration complaint; witness does not reply on the chain
Apr 11 Incident summary, authored by witness CYM-001190 States the failure was "sudden and without prior indication"

Contradictions

The Apr 11 incident summary against the Apr 2 email.

The witness wrote on April 11 (CYM-001190):

"The failure was sudden and without prior indication."

The witness was copied on April 2 (CYM-001033), where the supervisor wrote:

"Line 3 is vibrating again, worse than last month. We should look at it before the next run."

The Mar 19 report against the supervisor's testimony.

The witness's March 19 report states "no open maintenance items." The supervisor testified (Dep. 84:6-14):

"I told him the bearing needed replacing. I told him more than once."

Outline by topic

Topic 1: The witness received notice of the vibration. Fact to establish: the witness saw the April 2 email. Document: CYM-001033.

  1. You use the email address shown at the top of this document?
  2. Reading the recipient line, you were copied on this message?
  3. Do you have any reason to believe you did not receive it?
  4. You did not reply to this message, correct?
  5. Did you take any action in response to it?

Topic 2: The inspection interval changed before the failure. Fact to establish: the witness directed the change. Document: CYM-000412.

  1. This is an email you sent on March 4?
  2. Please read the second sentence aloud.
  3. Who decided to make that change?
  4. What was the interval before this email?
  5. Was anyone consulted before the change?

Anticipated problems

  • The March 19 report may not be the witness's own work. The document carries no signature block and the record does not establish who compiled it. Expect "that report is assembled by the shift leads." Establish authorship before using it.
  • "Without prior indication" is arguably about the mechanical failure rather than the complaint history. Expect the witness to draw that distinction. Pin down what they understood the phrase to mean at the time.

Not in the record

  • Nothing in the attached documents shows what the inspection interval was changed to, or who approved the change. The complaint asserts it doubled; no attached document states that. [NOT IN RECORD - confirm before asking a question that assumes it.]
  • No maintenance log, work order, or bearing replacement record appears in the production. If one exists, it is the central document for Topic 2 and is missing.
  • The supervisor's testimony refers to telling the witness "more than once." Only one written instance appears in the record. [DATES OF OTHER INSTANCES NOT IN RECORD.]