Use case: Deposition and witness preparation

You can use Gemini Enterprise to brainstorm potential questions for a deposition or witness interview, to help ensure that you cover all critical areas.

Example prompt

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

I am a litigator preparing for a deposition in a breach of contract case. Our
client, 'Supplier Corp.' is suing 'Buyer Corp.' for failure to pay $500,000 for
delivered goods.

I will be deposing the CFO of Buyer Corp. My goal is to establish:

1. That Buyer Corp. received the goods.
2. That they have not paid the invoices.
3. Their financial state at the time payment was due.
4. If there was any internal communication about the non-payment.

Generate a list of key deposition questions organized by topic.

Example output

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

Deposition Questions for CFO of Buyer Corp.

I. Background and Role

  • Please state your full name for the record.
  • What is your official title at Buyer Corp.?
  • How long have you held the position of CFO?
  • Please describe your primary responsibilities as CFO.

II. The Contract and Invoices

  • Are you familiar with the contract between Buyer Corp. and Supplier Corp. dated [Date]?
  • Were you involved in the approval process for this contract?
  • Are you aware that Supplier Corp. issued invoices totaling $500,000 to Buyer Corp. between [Date] and [Date]?
  • I'm showing you what's been marked as Exhibit 1. Do you recognize this as Invoice #1234 from Supplier Corp.?

III. Receipt of Goods and Non-Payment

  • To your knowledge, did Buyer Corp. receive the goods associated with these invoices?
  • Does Buyer Corp.'s accounting system show these invoices as received?
  • Does that same system show these invoices as paid?
  • As of today, has Buyer Corp. paid any portion of the $500,000 owed?
  • Why has payment not been made?

IV. Financial Condition and Internal Communications

  • What was the cash-on-hand position of Buyer Corp. around [Date payment was due]?
  • Did Buyer Corp. have a line of credit available at that time?
  • Have you had any discussions with anyone else at Buyer Corp., including the CEO, about the decision not to pay these invoices?
  • What was said in those conversations?
  • Were any emails, memos, or other documents created regarding the decision not to pay Supplier Corp.?