For this 320-page deposition transcript, create page-line summaries:

1. For each major topic discussed:
   - Page range where topic appears
   - Line numbers of key testimony
   - Exact quotes (with line citations)
   - Witness's position/claim
   - Credibility factors

2. Create index showing:
   - Topics in order discussed
   - Topics in order of legal importance
   - Cross-references between related topics
   - Impeachment opportunities

3. Flag testimony by type:
   - Admissions (page-line with exact quote)
   - Contradictions (compare to other testimony)
   - Evasive answers (page-line references)
   - Foundation issues (topics witness isn't qualified on)

From [witness name]'s deposition, create two versions:

Version 1: Plaintiff's Narrative
- Tell the story from plaintiff's perspective
- Highlight testimony supporting plaintiff
- Note admissions helpful to plaintiff
- Identify weaknesses in witness's account
- Point out what witness didn't say

Version 2: Defendant's Narrative
- Tell the same story from defendant's perspective
- Highlight testimony supporting defendant
- Note areas of witness's certainty
- Emphasize favorable facts
- Show consistent memory on key points

Format each as trial team memo (2-3 pages) with
page-line citations for every factual assertion.

Organize testimony by these topics:
1. Witness's background and knowledge
2. Timeline of events (chronological)
3. Product/document knowledge
4. Decision-making process
5. Communications with others
6. Knowledge of problems/risks
7. Actions taken (or not taken)
8. Injury circumstances

For each topic:
- Collect all related testimony
- Note page ranges
- Identify contradictions within topic
- Show what testimony supports/undermines
- Recommend trial designations

Create formatted outline that trial lawyers
can use immediately without reading 320 pages.

[Upload sample deposition transcript]

Produce three deliverables:
1. Page-line indexed summary (15 major topics, 2-3 pages)
2. Narrative summary from both perspectives (3 pages each)
3. Topic-based testimony compilation (organized by case themes)

Include:
- All citations formatted: "[Witness], Deposition p. XX:YY-ZZ"
- Exact quotes for key testimony
- Identification of strongest/weakest areas
- Cross-examination opportunities
- Trial designation recommendations

I have:
- [Witness name]'s prior statements
- Documents prepared by or signed by witness
- Email communications from witness
- Prior deposition testimony

Create cross-examination questions that:
1. Establish document authenticity
2. Explain inconsistencies between:
   - Document and witness's current story
   - Prior statement and current testimony
   - What witness said vs. what documents show
3. Lock in witness positions
4. Narrow witness's ability to explain away documents
5. Use witness's own words (direct quotes)

Format each question:
Q: [The question - specific, not argumentative]
Basis: [Document/statement supporting this line]
Purpose: [What it establishes]
Expected answer: [Most likely response]
Follow-up: [What to ask if evasive]

This witness previously stated (in [source]): "[Quote about X]"
But in deposition testified: "[Quote contradicting first statement]"

For EACH contradiction, identify:
1. Source 1 details (where made, date, context)
2. Source 2 details (where made, date, context)
3. Exact quotes from both (with citations)
4. Why contradiction matters legally
5. Documentary evidence supporting Source 1
6. Cross-examination questions establishing contradiction
7. Impeachment questions about why witness changed story
8. Strategic value (major/minor contradiction)

Create "Impeachment Matrix" showing:
- Timeline of contradictory statements
- Evolution of witness's story
- Documents witness didn't disclose/mention
- Areas where documents contradict witness

Analyze witness credibility on:

1. Bias/Motive
   - Financial interest in outcome?
   - Relationship to parties?
   - Statements about bias? (testimony or documents)
   - Demeanor suggesting bias?

2. Opportunity/Knowledge
   - Was witness actually present?
   - Had access to documents?
   - Qualified to make claims?
   - Consistent with known information flow?

3. Memory/Accuracy
   - How much time passed?
   - Does testimony match documents?
   - Contradictions within own testimony?
   - Evasive on specific points?
   - Uses "I don't recall" excessively?

4. Internal Consistency
   - Testimony consistent across time?
   - Testimony consistent across topics?
   - Explainable inconsistencies?
   - Deliberate contradictions?

Rate credibility: Strong / Moderate / Weak
List specific factors supporting rating.

Anticipate opposing counsel's cross-examination questions.

For each anticipated attack:
1. Identify the weakness opposing counsel will target
2. Develop redirect questions to rehabilitate witness
3. Create supporting documents to offer
4. Prepare explanations for apparent inconsistencies
5. Build foundation for witness to explain seeming contradictions

Format:
Expected Cross Q: [What opposing counsel will ask]
Vulnerability: [Why this hurts our case]
Redirect Q: [How we rehabilitate]
Supporting evidence: [Documents backing up redirect]
Witness preparation: [How to coach witness to answer]

[Upload witness deposition, prior statement, and key documents]

Develop complete cross-examination strategy:

1. Impeachment matrix (10 contradictions with citations)
2. Cross-examination outline (15-20 questions with purposes)
3. Credibility analysis (strengths and vulnerabilities)
4. Documentary evidence checklist
5. Redirect preparation (anticipated attacks and responses)
6. Question sequencing strategy
7. Demeanor/delivery notes

Make this practical for trial team to use during
actual cross-examination in courtroom setting.

From all documents in case, generate trial exhibit list:

For EACH exhibit:
1. Exhibit number and description
2. Document ID (Bates number)
3. Date of document
4. Source/author
5. Foundation witness (who can authenticate)
6. Relevance (how it supports/undermines position)
7. Purpose (what it proves)
8. Admission/Exception (if hearsay, what exception)
9. Objections (anticipate opposing arguments)
10. Related exhibits (documents it connects to)

Organize exhibits:
- By theme/case theory
- By witness (which witness introduces)
- By chronological order
- By evidentiary category

Include:
- Exhibit description for jury
- Simplified version if original is dense
- Demonstrative if complex
- Full version with annotations

Create table of authorities showing:

1. Each statute/rule cited in trial brief
2. Each case cited in trial brief
3. Each regulation cited

For each authority:
- Full citation format
- Pin cite (specific page/paragraph cited)
- Proposition it supports
- How introduced at trial
- Jury instruction correlation
- Expert report cross-references
- Trial brief section referencing it
- Which witness can testify about it
- Documentary evidence supporting it

Format as:
- Organized by subject matter
- Organized by order of trial presentation
- Organized by witness/expert testimony
- Organized by themes

Include conflict-checking:
- Any authorities cited by both sides?
- Any conflicting interpretations?
- Any circuit splits?
- Distinguish adverse authority?

Organize trial exhibits in multiple ways:

Physical Organization:
- Create exhibit binder for each witness
- Include only exhibits that witness introduces
- Mark foundation witness in exhibit notebook
- Create quick-access index tabs

Theme Organization:
- Theme 1 exhibits (all documents supporting)
- Theme 2 exhibits (all supporting documents)
- [Continue for all themes]
- Cross-reference exhibits appearing in multiple themes

Chronological Organization:
- All exhibits in date order
- Visual timeline showing exhibit placement
- Color-code by exhibitor/theme
- Mark key exhibits for jury focus

Technology Organization:
- Digital exhibit database with search
- Quick-pull system for trial (page number → document)
- Display format (how to show jury)
- Annotation system (highlighting key language)

For each exhibit, prepare foundation:

Foundation Questions (for each exhibit):
1. Recognition question ("Do you recognize this?")
2. Authenticity ("How do you know this is authentic?")
3. Date verification ("How do you know when created?")
4. Author identification ("Who created this?")
5. Business record foundation (if applicable)
6. Chain of custody (if physical evidence)
7. Completeness ("Is this the complete document?")
8. Accuracy of copies ("Is this a true copy?")

For complex exhibits:
- Expert foundation (expert qualifications)
- Technical foundation (technical evidence rules)
- Scientific foundation (Daubert requirements)
- Demonstrative foundation (explains how made)

Create exhibit-by-exhibit foundation checklist
so trial team never misses foundation.

[Provide case materials: trial brief, expected testimony, documents]

Build complete trial exhibits package:

1. Exhibit list (100+ items with all required information)
2. Table of authorities (all case law with pin cites)
3. Organized exhibit notebooks (by witness, by theme)
4. Foundation checklist (foundation questions for each exhibit)
5. Technology organization plan
6. Demonstrative exhibit strategy
7. Jury presentation order

Include coordination matrix showing:
- Which exhibit supports which fact
- Which witness introduces which exhibit
- Which case law supports exhibit admission
- Which jury instruction relates to exhibit

Create system for finding evidence instantly during trial:

Phase 1: Pre-Trial Setup
- Organize all trial documents in searchable database
- Create index by:
  * Document ID/Bates number
  * Topic/keyword
  * Date range
  * Exhibit number
  * Witness name
  * Page/line reference
- Test search speed (goal: document onscreen in <30 seconds)

Phase 2: During-Trial Access
- Trial counsel has laptop with database
- Backup system (tablet, printed index)
- WiFi or tethered connection for live search
- Real-time search results
- Hot-keys for frequently accessed documents

Phase 3: Search Protocols
- If witness testifies about document: search "Witness + Document ID"
- If testimony contradicts document: search "Contradiction + Keywords"
- If opposing counsel references exhibit: search "Exhibit #"
- If new fact emerges: search by topic and date

Example searches:
- "Email from [Person] to [Person] about Safety" → Results in 5 seconds
- "All communications about Defect Discovery" → Results in 10 seconds
- "Exhibit 45" → Opens instantly
- "Testimony about [Topic] on [Date]" → Links to deposition page

For trial preparation, create:

1. Master Document Index
   - All documents with:
   - Bates number
   - Exhibit number
   - Topic tags
   - Key word tags
   - Date
   - Source
   - Page count
   - Related documents

2. Digital Organization
   - All documents in PDF (searchable)
   - Bookmarks by exhibit number
   - Bookmarks by topic
   - Annotations highlighting key language
   - Comment bubbles explaining significance

3. Backup Systems
   - Printed exhibit binder (hardcopy backup)
   - Tablet with database
   - Laptop with database
   - Cloud backup (for WiFi access)

4. Contingency Plans
   - If technology fails, can use printed exhibits
   - If search doesn't work, hard copy index
   - If no WiFi, local database
   - Timer on searches (if takes >60 seconds, switch to hardcopy)

Create searchable tags for every document:

Topic Tags (search by subject):
- Knowledge of defect
- Testing/quality assurance
- Safety warnings
- Prior incidents
- Cost-benefit analysis
- Decision-making process
- Communications with regulators
- Customer complaints

Party Tags (search by who's involved):
- CEO email
- Engineer testimony
- Customer communication
- Competitor reference
- Regulatory letter
- Expert document

Date Tags (search by when):
- Pre-design phase
- Design phase
- Pre-launch phase
- Post-launch phase
- Post-incident phase
- By specific month/year

Relevance Tags (search by importance):
- Key evidence
- Supporting evidence
- Contradicting evidence
- Impeachment material
- Foundation document
- Expert support

Create search menu so trial team can find:
"Documents about [Topic] involving [Party] from [Date] that are [Relevance level]"
Results in seconds.

Create web of connections showing:

For each exhibit:
1. What other exhibits does it relate to?
2. How do they connect?
3. What does relationship show?

Examples:
- Email about Safety (Exhibit 45)
  Links to: Meeting notes (Exhibit 47), Internal memo (Exhibit 50),
  Regulatory letter (Exhibit 52)
  Shows: Escalating knowledge of risk over time

- Test Results (Exhibit 78)
  Links to: Cost-benefit analysis (Exhibit 82), Decision memo (Exhibit 85),
  Launch email (Exhibit 89)
  Shows: Company knew about problem before launch

Create visual link map showing:
- Central fact (center of diagram)
- All exhibits supporting that fact (radiating out)
- How exhibits connect to each other
- Strongest to weakest exhibits

Use during trial to show jury:
"These five exhibits together prove [claim]"
Rather than presenting exhibits in isolation.

[Provide case document set: 200+ documents with various topics/dates/parties]

Build complete evidence search and retrieval system:

1. Master document index (searchable spreadsheet)
2. Digital document organization (with bookmarks and annotations)
3. Search strategy protocols (10 common searches tested)
4. Keyword and topic tagging system
5. Exhibit linking map (showing connections)
6. Real-time access plan (how to retrieve during trial)
7. Backup systems documentation
8. Speed testing results (time to retrieve each exhibit)

Demonstrate with 10 live searches:
- "Show me documents about X from 2023"
- "Find contradiction about Y"
- "Locate all exhibits related to Z"
- Etc.

Goal: All searches return correct results in <30 seconds.

Extract ALL events from ALL sources:

From documents (dates documents created):
- January 15, 2021: Design team meeting about specifications
- February 3, 2021: First safety testing completed
- March 12, 2021: Design modified based on test results
[Continue with every dated document]

From testimony (events witnesses testify about):
- "Around March 2021, we discussed..."
- "In early April, I learned that..."
[Continue with every date witness mentions]

From other sources:
- Patent filing dates
- Regulatory submission dates
- Customer complaint dates
- Incident dates

Consolidate into single timeline showing:
1. Event date (actual or approximate)
2. What happened
3. Who was involved
4. Which documents relate to it
5. Which testimony addresses it
6. Significance (background/key/critical)
7. Which party benefits (Plaintiff/Defendant/Neutral)

Build visual timeline showing:

Horizontal timeline bar showing:
- Overall case time period (2018-2024)
- Critical periods (highlighted)
- Major events (with icons)
- Key turning points (marked)
- Injury/incident (prominently marked)

Color coding:
- Blue: Defendant's knowledge building
- Red: Warning decisions
- Green: Safety actions taken
- Yellow: Problem indicators
- Orange: Missed opportunities

For jury trial, create simplified version:
- 5-7 key dates that tell the story
- Large text (readable from back of courtroom)
- Simple icons/graphics
- One-sentence description per date

For expert presentation, detailed version:
- 50+ dates showing full evolution
- All supporting documents referenced
- All witness testimony tied to dates
- Every decision point marked

Analyze timeline for gaps:

Identify periods with NO documents:
- "March 15-April 30, 2021: No documents produced"
- Why no documents?
- What should have been documented?
- Where are missing documents?
- Spoliation implications?

Identify silent parties:
- Who should have been in communications?
- Who was excluded from key meetings?
- Who didn't receive critical information?
- Why were they silent?

Identify events not documented:
- Testimony about events with no supporting docs
- Is testimony credible without documentation?
- Should there be documents (suggests concealment)?
- What's the implication for fact-finder?

Create "Gap Analysis" showing:
- When gaps exist in timeline
- What should be there
- Implications of gaps
- Theory of the case implications

Using timeline, construct narrative:

Version 1: Plaintiff's Story
"In January 2021, the company began designing [Product].
From the beginning, they had concerns about safety.
Documents show [Concern 1]. Testimony shows [Concern 2].

In March 2021, testing revealed problems.
Rather than fix them, the company [Decision].
Evidence shows [Document A] and testimony [Witness B].

In June 2021, the company launched despite knowing risks.
[Exhibit C] shows [damaging fact].
[Testimony of Witness D] confirms [critical point].

In August 2021, the injury occurred.
Because they knew about the risk and did nothing,
the company is responsible."

Version 2: Defendant's Story
[Alternative narrative using same timeline]

Create both narratives so:
- Trial team understands both theories
- Can anticipate opposing arguments
- Can prepare responses
- Understand what jury will hear

[Upload documents spanning 3+ years and sample depositions]

Build comprehensive case timeline:

1. Event-by-event chronology (50+ dated events)
2. Visual jury timeline (5-7 key dates)
3. Expert timeline (50+ detailed dates with support)
4. Gap analysis (identify 5-10 significant gaps)
5. Plaintiff narrative (showing timeline supports plaintiff)
6. Defendant narrative (showing timeline supports defendant)
7. Knowledge timeline (when each party knew what)
8. Decision-point analysis (key turning moments)

Include:
- Every document referenced in timeline
- Every witness testimony cited
- Every exhibit linked to dates
- Demonstrative graphics prepared
- Jury presentation version
- Trial notebook references

For each testifying witness, create binder with:

Section 1: Overview
- Witness background summary
- Role in events
- Key topics witness will testify about
- Trial schedule/timing

Section 2: Key Documents
- All documents witness created
- All documents witness reviewed
- All documents contradicting witness
- All documents supporting witness

Section 3: Deposition Preparation
- Copy of deposition transcript (key pages highlighted)
- Videographer contact info
- Video clip locations
- Deposition objections to review

Section 4: Anticipated Questions
- Direct examination questions (how we'll ask)
- Expected cross-examination questions
- Objections we'll make
- Objections opposing counsel will make

Section 5: Theme Reminder
- One-page summary of case theme
- How witness's testimony supports theme
- Key points witness should make
- Language witness should use/avoid

Section 6: Logistics
- Trial date, time, location
- Where to arrive, who to meet
- Parking information
- What to wear
- Who to contact with questions

For witness's testimony, compile:

Documents Witness Created:
- All emails authored
- All reports prepared
- All memos written
- All handwritten notes

Documents Witness Reviewed:
- Documents provided to witness
- Documents witness references in testimony
- Documents contradicting witness
- Documents supporting witness

Organization:
- Chronological order
- With "sticky notes" showing:
  * Where witness references this
  * Why this document matters
  * How it supports testimony
  * Any contradictions to address

Annotation:
- Highlight key language
- Add margin notes explaining relevance
- Cross-reference to deposition
- Cross-reference to testimony outline

Prepare witness to say:
"This is the email I sent on [Date] regarding [Topic].
It shows [Key Point].
This supports my testimony about [Subject]."

For each topic witness will address:

Create question-and-answer pairs:

Q: (Question counsel will ask on direct)
A: (Ideal answer - one or two sentences)

Q: (Question opposing counsel will ask on cross)
A: (Best answer witness can give)
   NOTE: Don't argue, don't volunteer, answer only what asked

Difficult Questions (things opposing counsel will attack):

Q: (Most difficult question)
A: (How to answer honestly while minimizing damage)
   COACHING: Here's why this matters... Here's how to frame answer...

Q: (Second difficult question)
A: (Prepared answer)
   COACHING: Don't get defensive. Stay calm. Answer specifically.

Compound Questions (opposing counsel will try tricks):

Q: "You said [X] in your deposition, but today you said [Y] - isn't it true you're not being consistent?"
COACHING: "Actually, those two statements aren't inconsistent because..."
A: [Prepared explanation]

Q: "Isn't it true that if [Condition A], then [your position is false]?"
COACHING: "Let me explain why that's not necessarily true..."
A: [Prepared answer]

Practice witness answering:
- Opens mouth and does it
- Doesn't look uncertain
- Answers complete thought (not just "yes")
- Makes eye contact with jury

If opposing counsel attacks witness credibility, prepare:

Anticipate Attack Area 1: [Topic]
- What opposing counsel will argue witness is wrong about
- Documents supporting what witness said
- Explanations for apparent inconsistencies
- Other evidence corroborating witness

Redirect Questions:
Q: "You heard [opposing counsel's point]. Let me ask you about [background]..."
A: [Answer that explains the apparent inconsistency]

Q: "Is there anything in [Document X] that you want to clarify?"
A: [Clarification]

Q: "In your experience, is [opposing counsel's interpretation] reasonable?"
A: [Why not, with explanation]

Corroborating Evidence:
- Document A shows [supporting fact]
- Witness B testified [corroborating fact]
- Expert report shows [technical support]

Create "Redirect Script" showing exactly what to ask
to rehabilitate witness on each anticipated attack area.

[Identify 3-4 witnesses and provide their depositions + key documents]

Build complete witness preparation materials:

For each witness:

1. Witness binder
   - Background/role summary
   - Key document compilation
   - Topic guide
   - Direct examination outline
   - Cross-examination predictions
   - Anticipated difficult questions
   - Redirect preparation

2. Q&A preparation document
   - 20 direct examination questions with ideal answers
   - 20 cross-examination questions with prepared answers
   - 5 difficult questions with coaching notes
   - 5 impeachment attempts with redirect strategy

3. Deposition review summary
   - Key testimony (with page references)
   - Contradictions to address
   - Admissions to acknowledge
   - Evasive answers to fix
   - Video clip locations

4. Testimony outline (for trial presentation)
   - Topics in order
   - Key points under each topic
   - Supporting documents for each point
   - Jury theme integration

Make this practical so witness can review in 1 hour
and feel prepared to testify.

For your jurisdiction, draft jury instructions on:

1. Liability Issues (elements of claim):
   - For [Cause of Action], you must find:
     Element 1: [Instruction language]
     Element 2: [Instruction language]
     Element 3: [Instruction language]
   - Cite to pattern instructions
   - Modify if needed for specific case

2. Burden of Proof
   - Preponderance of evidence instruction
   - Clear and convincing standard (if applicable)
   - Beyond reasonable doubt (if any criminal element)

3. Evidence Issues
   - Expert opinion instruction
   - Circumstantial evidence instruction
   - Documentary evidence instruction
   - Impeachment instruction (credibility)

4. Special Instructions
   - Willful/reckless conduct
   - Punitive damages (if applicable)
   - Causation instructions
   - Comparative fault (if applicable)

5. Damages
   - Economic damages instruction
   - Non-economic damages instruction
   - Lost wages/future earnings
   - Pain and suffering

For each instruction:
- Provide full text
- Cite to pattern instructions
- Identify any customization needed
- Note any objections anticipated
- Cite case law supporting instruction

Create special verdict form requiring jury to find:

Interrogatory 1: Do you find that [Defendant] owed [Plaintiff] a duty?
Answer: Yes / No
[If No, go to Interrogatory X. If Yes, continue.]

Interrogatory 2: Do you find that [Defendant] breached that duty?
Answer: Yes / No
[Describe breach]

Interrogatory 3: Do you find that [Plaintiff] was injured?
Answer: Yes / No
[Describe injury]

Interrogatory 4: Do you find that [Defendant]'s breach caused [Plaintiff]'s injury?
Answer: Yes / No

Interrogatory 5: What is the amount of [Plaintiff]'s damages?
Answer: $ ________________

Interrogatory 6: Do you find that [Defendant] acted with [willful disregard]?
Answer: Yes / No
[If Yes, assess punitive damages: $ ________________]

For each interrogatory:
- Make clear and unambiguous
- Require findings on every element
- Organize logically
- Include instructions
- Test for ambiguity

Special verdict advantages:
- Jury must decide every element
- Appellate record shows jury's reasoning
- Can test jury's consistency (element finding without liability)

Expected Instruction Objections:

1. Objection: "Instruction misstates law"
   Opposing counsel will argue: [Expected argument]
   Response: [Case law supporting your instruction]
   Alternative: [Revised language addressing concern]

2. Objection: "Instruction is argumentative"
   Opposing counsel will argue: [Expected argument]
   Response: [Case law showing instruction is neutral]
   Alternative: [Revised language]

3. Objection: "Instruction unfairly prejudices [side]"
   Opposing counsel will argue: [Expected argument]
   Response: [Case law supporting instruction as given]
   Alternative: [Compromise language]

4. Objection: "Missing instruction on [topic]"
   Response: [Instruction is included as #X]
   Alternative: [Instruction on broader topic covers this]

For each anticipated objection:
- Be prepared with case law
- Have alternative language ready
- Don't be defensive (judge won't grant objections lightly)
- Offer to revise if legitimate concern

Pre-Trial Briefing:
- Submit proposed instructions early
- Explain any customization
- Cite supporting case law
- Anticipate objections
- Address them before opposing counsel raises

Whether jury trial or bench trial, prepare:

FINDINGS OF FACT:

For each critical fact (in order):
1. [Specific factual finding]
   Evidence supporting finding:
   - Exhibit: [Document citation]
   - Testimony: [Witness, page-line]
   - Expert opinion: [Expert, page-line]

2. [Next factual finding]
   [Supporting evidence]

[Continue for all essential facts]

CONCLUSIONS OF LAW:

For each element of claim:
1. [Element name]: [Legal conclusion]
   Authority: [Case citation]
   Factual basis: Findings #1-3 above establish that...
   Application: Because [factual findings], [legal conclusion] follows.

2. [Next element]
   [Same format]

Damages:
1. Economic damages calculated as:
   [Detailed breakdown with evidence]
   Total: $ ________

2. Non-economic damages:
   [Basis and calculation]
   Total: $ ________

Liability of [Defendant]:
- The evidence clearly establishes [Defendant] is liable because...
- [Defendant]'s arguments that [argument] fail because...

Use findings for jury instructions alignment:
- Every jury instruction has supporting findings
- Every finding has jury instruction corroboration
- Appellate record is clear and well-supported

[Provide case details: jurisdiction, type of case, key disputes]

Build complete jury instructions and verdict forms package:

1. Proposed jury instructions (full text)
   - 10-15 instructions on key issues
   - Pattern instruction citations
   - Custom modifications explained
   - Objection-resistant language

2. Special verdict form
   - Interrogatories on each element
   - Logical flow with contingent instructions
   - Clear and unambiguous questions
   - Space for jury findings

3. Objection brief
   - Anticipated opposing objections (5-10)
   - Case law responses for each
   - Alternative language proposals
   - Justification for customizations

4. Findings of fact & conclusions of law
   - 20+ findings supporting your case
   - Each finding tied to evidence
   - Conclusions of law for each element
   - Damages calculation explained

5. Coordinating document
   - Shows which instruction corresponds to which finding
   - Shows which verdict form item corresponds to verdict form
   - Shows which evidence supports each finding
   - Shows which case law supports each conclusion

Format for pre-trial submission to judge.

MOTION FOR NEW TRIAL

I. INTRODUCTION
The verdict is contrary to the weight of evidence because...

II. STANDARD
[Cite standard for new trial in your jurisdiction]

III. GROUNDS FOR NEW TRIAL

A. Verdict is Against Weight of Evidence
1. Preponderance of evidence showed [Plaintiff/Defendant] position
   Evidence:
   - Exhibit X showed [fact]
   - Testimony of Witness A stated [fact]
   - Expert opinion of Dr. B established [fact]
2. Jury ignored [key evidence]
3. Jury misapplied law as instructed

B. Errors in Jury Instructions
1. Instruction on [Element] misstated the law by...
   Correct law: [Case citation]
   Jury received: [Wrong instruction]
   Prejudice: This error favored [Opponent]

C. Newly Discovered Evidence
1. After verdict, we discovered [Document/Testimony]
2. This evidence is [material/exculpatory/impeaching]
3. It could not have been discovered with due diligence
4. It would probably produce different verdict

D. Procedural Errors
1. Judge erroneously admitted [evidence]
   Prejudicial effect: This swayed jury on [element]
2. Judge erroneously excluded [evidence]
   Prejudicial effect: Jury was left with incomplete picture

IV. RELIEF REQUESTED
[Defendant/Plaintiff] respectfully requests the Court grant
this motion for new trial and order a new trial on all issues.

Include:
- Page-line citations to trial transcript
- Exhibit citations
- Case law for every argument
- Specific prejudicial effect of each error
- Why error probably affected verdict

POST-TRIAL BRIEF

I. VERDICT IS SUPPORTED BY EVIDENCE (if you won) OR
   VERDICT IS AGAINST WEIGHT OF EVIDENCE (if you lost)

A. Standard
[Citation to law on new trial standard]

B. Evidence Supporting Verdict
1. [Element 1] - Clearly Established
   "The evidence overwhelmingly showed [Element]:"
   - Exhibit A showed [supporting fact]
   - Witness B testified [supporting fact]
   - Expert C opined [supporting fact]
   Opposing party's contrary argument fails because...

2. [Element 2] - Clearly Established
   [Same format]

[Continue for all elements]

C. Jury's Verdict Was Reasonable
Even if evidence was close on [Element], jury could reasonably
conclude [fact] because [explanation of jury's reasoning].

II. ERRORS IN JURY INSTRUCTIONS

[For each jury instruction error you raised]:

A. Instruction Misstated Law on [Element]
1. Pattern Instruction Says: [Quote pattern instruction]
2. Given Instruction Said: [Quote jury instruction]
3. The Error: [Explanation of how instruction was wrong]
4. Authority for Correct Law: [Case citations]
5. Prejudice: [Specific way error affected verdict]

B. Missing Instructions
[Explain why no instruction on [topic] was necessary/required]

III. TRIAL JUDGE'S EVIDENTIARY RULINGS

A. Admission of [Evidence]
Ruling: Court admitted [evidence]
Authority for Ruling: [Case law allowing admission]
Effect: [Evidence was important to jury decision]
Prejudice: [No prejudice because evidence was admissible]

B. Exclusion of [Evidence]
Ruling: Court excluded [evidence]
Authority for Ruling: [Case law supporting exclusion]
Effect: [Evidence was not critical to verdict]
Prejudice: [No prejudice because verdict would be same]

IV. CONCLUSION

The jury's verdict is supported by substantial evidence.
The judge's instructions and evidentiary rulings were correct.
Therefore, judgment should be entered on the verdict.

Respectfully submitted,
[Attorney Name]

Build comprehensive appellate record:

I. DESIGNATION OF RECORD

A. Trial Transcript
- Identify which volumes/pages are relevant
- Create index of key testimony
- Mark locations of trial judge's rulings
- Note any trial judge comments explaining rulings

B. Exhibits
- List all trial exhibits
- Identify physically impossible to reproduce
- Note which exhibits specifically referenced on appeal
- Organize for appellate court review

C. Motions and Pleadings
- Original complaint
- Answer and affirmative defenses
- Motions practice (motions in limine, summary judgment, etc.)
- Judge's rulings on motions
- Any trial judge's opinions

D. Jury Materials
- Jury instructions (as given)
- Proposed jury instructions (not given)
- Jury verdict form
- Jury verdict
- Jury polling (if any)

II. PRESERVATION OF RECORD

Ensure appellate issues are properly preserved:
- Objection at trial: [Cite trial transcript]
- Proper standard: [Case law]
- Exception taken: [Trial record citation]
- Ruling: [Judge's exact ruling with citation]

For each appellate issue:
- Trial judge made ruling
- Attorney objected properly
- Exception taken properly
- Record reflects error preserved

III. APPELLATE THEORY DEVELOPMENT

A. Issue 1: [Legal issue for appeal]
   Trial ruling: [Citation to trial transcript/order]
   Applicable law: [Case citations]
   Error: [How judge applied law incorrectly]
   Prejudice: [How error affected verdict]
   Relief: [What appellate court should do]

B. Issue 2: [Next legal issue]
   [Same format]

IV. APPELLATE BRIEF FRAMEWORK

A. Statement of Issues
- Issue 1: [Precise statement of what judge did wrong]
- Issue 2: [Next issue]

B. Standard of Review
- Issue 1 standard: [Abuse of discretion/de novo review/etc.]
- Case law supporting standard: [Citations]

C. Facts
- Relevant facts for each issue: [In neutral tone]
- Trial record citations: [Page-line references]

D. Argument
- For each issue:
  1. Rule: [State law clearly]
  2. Application: [Apply to facts]
  3. Judge erred: [Explain error]
  4. Prejudice: [Why it matters]

E. Conclusion
- Request for reversal/remand

Coordinate post-trial brief with appellate brief:
- Post-trial brief defends trial judge's rulings
- Appellate brief attacks trial judge's rulings
- This allows full development of record

Create organized appellate record:

Physical Organization:
1. Trial Transcript (volumes marked with tabs)
   - Mark key pages for easy reference
   - Create mini-index of important testimony
   - Color-tabs marking critical pages

2. Exhibits Binder (numbered and organized)
   - Exhibit list with descriptions
   - Exhibits in trial number order
   - Cross-reference to trial transcript
   - Quality reproduction (readability for court)

3. Motions and Pleadings Binder
   - All motions to trial judge
   - Judge's written orders on motions
   - Any oral rulings (cite to transcript)
   - Jury instructions (proposed vs. given)

4. Jury Verdict Materials
   - Verdict form
   - Jury verdict (signed by foreperson)
   - Jury poll results (if any)
   - Any post-verdict jury questioning

5. Post-Trial Filings
   - Motion for new trial
   - Post-trial briefs
   - Judge's rulings on post-trial motions

Digital Organization:
- All documents in PDF (fully searchable)
- Bookmarks matching physical organization
- Hyperlinks between related documents
- Exhibits linked to transcript references
- Full-text search capability

Index Materials:
- Alphabetical exhibit index
- Witness index (who testified about what)
- Key facts index (where proven in record)
- Legal issues index (where addressed)
- Case law index (where cited)

This organizational system makes appellate work efficient
and ensures nothing gets missed.

[Provide trial materials: verdict, trial transcript, exhibits, jury instructions]

Build complete post-trial documentation package:

1. Motion for New Trial
   - Identify 2-3 grounds (weight of evidence, jury instruction error, new evidence)
   - Develop full argument for each ground
   - Cite trial transcript with page-line references
   - Explain prejudicial effect of each error
   - Request specific relief

2. Post-Trial Brief
   - Defend verdict (if you won) or attack verdict (if you lost)
   - Address each element of claim
   - Explain jury's reasoning was sound
   - Defend against any jury instruction errors
   - Defend judge's evidentiary rulings
   - Argue judgment should be entered

3. Appellate Brief Preparation
   - Identify 2-3 appellate issues (legal errors by judge)
   - Develop statement of issues
   - Research applicable law
   - Prepare facts supporting each issue
   - Outline argument for each issue
   - Note what relief you'll request

4. Appellate Record Preparation
   - Create comprehensive index of trial transcript
   - Organize exhibits for appellate presentation
   - Compile motions and pleadings
   - Organize jury instructions and verdict
   - Create research index (by issue, by fact, by case law)

Make this practical for appellate attorney taking
case to appeal court.