---

name: casesim-client-q-and-a-prep
description: Use when an attorney needs to prepare a client for a deposition, witness statement, mediation session, or court testimony. Coaches the attorney through building a question bank from the case file, scoring question difficulty, running roleplay rehearsal (with Louis playing opposing counsel), critiquing answer quality, and running a final stress-test under interruption and time pressure. Covers privilege boundaries, conflicting evidence, and personal weak points. Produces a question bank, answer-coaching notes, and rehearsal log.
license: MIT
metadata:
id: casesim.client-Q-and-A-prep
category: casesim
jurisdictions: [multi]
priority: P1
intent: [litigation-prep, deposition, witness-prep, mediation]
related: [casesim-cross-examination-rehearsal, casesim-judge-bench-perspective, casesim-opposing-counsel-simulator, casesim-fact-pattern-builder, academy-litigation-game-coach]
source: Louis — HAQQ Legal AI (github.com/sboghossian/mini-claude-for-legal)
version: "1.0"

Client Q&A Prep — Deposition, Witness Statement, and Mediation Coaching

When to use this

Invoke when:

• An attorney is preparing a client for a deposition
• A client is submitting a witness statement and needs to be ready for follow-up questioning
• A party is attending a mediation where they will be questioned by the mediator or opposing counsel
• A client is testifying in court or before a tribunal (civil or commercial)
• An attorney wants to rehearse a client's narrative before a settlement negotiation

Jurisdictional applicability: deposition procedures vary significantly by forum. The US adversarial deposition model differs from Lebanese civil procedure (where pre-trial witness examination is limited), DIFC arbitration (where witness statements are primary and cross-examination at hearing is more constrained), and KSA Commercial Court practice. Calibrate the coaching intensity and procedure to the actual forum.

Inputs

Input	Required	Notes
Case summary / key facts	Yes	Who are the parties, what is the dispute, what happened?
Client's role	Yes	Fact witness, party witness, expert witness
Forum	Yes	Deposition (US), DIFC arbitration, Lebanese court, mediation, etc.
Key documents	Recommended	Contracts, emails, prior statements, relevant records
Privilege scope	Recommended	Attorney-client and work-product boundaries for this client
Known weak points	Optional	Prior testimony, social media, conflicts of interest, prior inconsistencies
Opposing counsel profile	Optional	Firm, known style, prior cross-examination patterns

Process

Step 1: Build the Question Bank

From the case file, Louis constructs a question bank organized by topic:

Opening narrative questions (always appear; shape how the client frames themselves):

• "Tell me about yourself and your role at [company]."
• "Walk me through your involvement in [key event]."
• "How long have you worked there, and who did you report to?"

Key fact questions (derived from the specific facts):

• What the client directly observed vs. was told vs. inferred
• Source of knowledge for each material fact ("how do you know that?")
• Documents the client authored, received, forwarded, or was copied on

Conflicting evidence questions (where the record shows inconsistency):

• Prior emails that seem to contradict the client's current position
• Statements made in earlier depositions or declarations
• Social media posts or external communications relevant to the matter

Documents under attack (specific documents likely to be put to the client):

• For each: who drafted it, what does it mean, what was the client's state of mind

Privilege boundary questions:

• Questions designed to pierce attorney-client privilege (indirect approaches)
• Questions designed to discover work product
• The client must know how to respond without inadvertently waiving privilege (redirect to counsel, do not explain privileged communications)

Personal weak points:

• Prior testimony in other proceedings
• Social media activity during the relevant period
• Conflicts of interest or financial interests relevant to the case
• Credibility vulnerabilities (prior conviction, prior inconsistent statement on an unrelated matter)

Step 2: Score Question Difficulty

Each question is scored 1–5:

• 1 (Routine): Uncontroversial facts the client knows well
• 2 (Attention required): Facts requiring precise language; small errors matter
• 3 (Significant): Documents or events where the record could be read multiple ways
• 4 (High-risk): Questions designed to create or exploit inconsistency; privilege boundary proximity
• 5 (Critical): Questions that go directly to the heart of liability or credibility; a bad answer here is case-changing

Focus rehearsal time on Level 3–5 questions.

Step 3: Roleplay Rehearsal

Louis plays opposing counsel. Behavioral modes:

• Baseline: professional, methodical questioning as a competent but not aggressive counsel
• Pressure mode: interrupts frequently, asks compound questions, uses silence as a tool
• Aggressive mode: raised stakes, leading questions, attempts to get the client to commit to damaging positions

The attorney directs which mode to use and when to escalate.

Coaching focus areas during rehearsal:

• Rambling: client gives too much information; answers go beyond what was asked
• Speculation: client answers what they think must have happened rather than what they know
• Volunteering: client introduces new information that was not asked for
• Imprecision: client uses approximations ("around," "maybe," "I think") on facts that are documentable
• Hedging when clarity is needed: over-qualified answers on simple documented facts look evasive

Step 4: Critique and Refine

After each answer, Louis provides structured feedback:

• What was strong (accurate, concise, appropriately limited to knowledge)
• What needs adjustment (and why: volunteered, speculative, over-explained, inconsistent with document X)
• Suggested rephrase (if the answer structure, not the fact, is the problem)

The attorney and client iterate until the answer set is stable.

Step 5: Stress Test

Final rehearsal run:

• Full simulated session at speed with time pressure (limited minutes per question set)
• Random interruption ("wait — you said earlier… [invented inconsistency]") to test whether the client handles pressure calmly
• Back-to-back difficult questions without breaks

The attorney reviews the stress-test log and decides whether more prep is needed.

Output

At the end of each session Louis produces:

1. Question bank (full list, scored by difficulty, with notes)
2. Answer coaching notes (per question: what to say, what to avoid, how to respond to follow-ups)
3. Rehearsal log (timestamped record of questions asked, answers given, coaching notes applied)

Hard limits

Louis will not:

• Coach a client to fabricate facts or give knowingly false testimony
• Help a client conceal documents that are subject to disclosure obligations
• Draft scripts that instruct the client to misrepresent their knowledge or memory
• Advise a client to hide or destroy evidence

If a user request crosses these lines, Louis declines and explains why.

Jurisdictional notes

Forum	Key preparation differences
US Deposition	Broad scope; counsel can object but client must answer unless privilege; video-recorded; transcript binding
DIFC / LCIA Arbitration	Witness statement primary; oral examination at hearing is more constrained; tribunal controls the process
Lebanese Civil Court	Oral examination by judge rather than by parties; preparation focuses on judge's likely questions rather than counsel's
KSA Commercial Court	Written evidence primary; oral testimony limited; preparation focuses on written statement accuracy
Mediation	Non-compulsory; client should be prepared for the mediator's probing questions and for informal dialogue with the opposing party

Related skills

• [[casesim-cross-examination-rehearsal]]
• [[casesim-judge-bench-perspective]]
• [[casesim-opposing-counsel-simulator]]
• [[casesim-fact-pattern-builder]]
• [[academy-litigation-game-coach]]