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Witness interview plan for case preparation

Prepare a source-linked witness interview plan from pleadings and evidence. For solicitors and investigations teams.

5 min read

Nothing here is legal advice. A draft is a starting point for a qualified person, not a substitute for one.

Use these prompts to prepare an interview plan that can be followed in the room and checked against the case materials. They are for solicitors and investigations teams working with pleadings, documents and known issues before taking witness evidence.

Nothing here is legal advice. The output is a draft work product. A qualified person must decide the interview approach, the questions to ask and how any evidence should be used.

Choose the right starting prompt

Start with Build the master interview plan if you have enough material to map the whole interview. It creates a chronology-led plan and a separate document-led section. This is normally the working document for the interviewer.

Use the other prompts where the work has a narrower problem:

If you have Use this prompt What you get
A chronology but no usable questions Turn a chronology into questions Questions ordered by event, with gaps exposed
A small number of important documents Prepare document-led interview questions Questions on creation, receipt, meaning and missing context
Conflicting accounts or an incomplete bundle Test inconsistencies and evidence gaps An issue matrix and neutral testing questions
A near-final plan Run the pre-interview quality check A corrected plan and an interviewer run sheet

Key point

Start from the source

Ask for the witness's own account before using a document to test, clarify or challenge it.

Prepare the material before pasting it

Give the prompt an evidence index rather than an unlabelled block of text. For every document, include its document ID, date, type, author, recipient and page or paragraph reference. If the document is an email chain, identify which messages and attachments are included. A plan cannot reliably distinguish a missing attachment from an irrelevant one if the input does not say.

For the pleadings, include the pleading name and paragraph number. Do not reduce the pleading to a broad issue label such as “knowledge” or “loss”. Paste the relevant wording or a careful summary with its paragraph reference. The plan needs to show what is alleged, not merely the team’s recollection of it.

Set out known issues separately. Examples include an uncertain meeting date, a disputed document author, a witness who joined after the event, or a gap in the message record. This stops the model treating an unresolved point as established fact.

Note

Keep source labels stable

Use the same document IDs in the evidence index, chronology and interview plan. Changing DOC-14 to “the April email” makes checking slower and creates avoidable errors.

Build questions in two passes

First, obtain an account by event. Ask what happened, who was present, what was decided, what the witness did next and what records were created. Then move to the documents. Ask whether the witness created, received, read, sent, stored or acted on the document, before asking what particular wording meant.

This order matters where a document may be incomplete, retrospective or part of a longer chain. It also makes it easier to record whether the witness is describing direct knowledge or repeating something they heard later.

When using the master prompt, review the two tables separately:

  1. Check the event table for a continuous sequence. There should be no unexplained jump from an early event to a later email or meeting.
  2. Check the document table for the documents that support, qualify or contradict each event. Include drafts, attachments and adjacent communications where their absence may matter.
  3. Move material questions from the known-issues section into the relevant event block. A known issue should not remain detached from the point where it arose.
  4. Keep a short closing section. It should ask about further records, additional people, corrections and follow-up, rather than assuming the supplied bundle is complete.

Watch out

Do not turn an allegation into a question premise

If the pleadings allege an event, ask the witness for their account and cite the allegation. Do not phrase the allegation as if it has already been proved.

Check the output before relying on it

A fluent plan can still be wrong. Check every event heading, factual proposition and document description against the materials. In particular, look for a source reference that points to the wrong page, a date imported from a different document, or a statement that silently combines two accounts.

The output needs correction if it does any of the following:

What you see What it may mean What to do
A confident statement with no source The point may have been inferred Mark it To verify or remove it
A document described as proving a fact The distinction between record and fact has been lost Recast it as a question for the witness
Questions on a document before any account of the event The sequence may be unnecessarily leading Add open event questions first
A gap described as an established fact The materials may be incomplete or ambiguous Identify the missing source or instruction needed

Check

A usable plan has a trail

You should be able to trace each material question back to a pleading paragraph, document reference, known issue or stated interview objective.

Check the questions aloud. Split compound questions such as “When did you receive the message and why did you not respond?” into separate questions. Mark terminology that the witness may not use. If the plan refers to “the approval process”, identify the document or person that defines it.

Handle sensitive material carefully

Do not paste material you are not authorised to use. Remove unnecessary personal data where a redacted extract will do. Keep the source labels and the relevant wording, because over-redaction can make a question impossible to check. Follow your organisation’s approved handling process and the applicable service settings. Features and limits can vary, so check the xAI documentation overview before deciding what material to submit.

Stop

Do not treat the draft as a witness account

The plan records questions and source-linked issues. It does not establish what the witness will say or what a document means.

When the prompts do not work

If the output is too general, do not ask for “more detail”. Add the missing pleading paragraphs, document IDs, dates and witness role, then run the narrower prompt that matches the gap. If citations are wrong, provide a cleaner evidence index and require page or paragraph references again. If the plan chooses between conflicting accounts, rerun it with the conflicting passages identified and instruct it to preserve both accounts.

Where the material remains incomplete, keep the uncertainty visible. Use Clarify before interview, identify the missing item or instruction, and let the qualified person decide whether the interview can proceed.

Copy-ready prompts

5 prompts. Open one to read it, or take the whole pack.

1Build the master interview planUse this first when you have the pleadings, a document bundle and a list of known issues. It produces the main plan for the interviewer.
Prepare a witness interview plan for [witness name and role] in [matter name]. This is a drafting work product for review by a qualified person, not legal advice.

Materials:
- Pleadings: [paste pleadings, or a structured summary with document name, date and paragraph references]
- Available evidence: [paste evidence index and relevant documents, with document ID, date, author, recipient, page or paragraph reference]
- Known issues: [paste list]
- Witness background and expected involvement: [paste]
- Interview purpose and deadline: [paste]

Create a plan in this exact format:

1. Scope and assumptions
   - State the witness's apparent role, the period covered and the issues the materials appear to address.
   - List every material assumption separately.
   - Identify missing materials or unclear references. Do not infer their contents.

2. Event-by-event interview plan
   Use a table with these columns: Event/date; issue; relevant pleading reference; relevant document ID and page/paragraph; facts to establish; open questions; follow-up questions; documents to show the witness; point requiring corroboration.
   - Put events in date order where dates are known.
   - Start each topic with open, non-leading questions.
   - Add focused follow-up questions only where they test a specific account, document, date, communication or decision.
   - Separate what the witness directly saw, said, did or received from what they may have learned from someone else.

3. Document-by-document questions
   Use a table with these columns: Document ID; document date; apparent relevance; authenticity, creation, receipt, circulation and storage questions; substantive questions; conflicts or gaps.

4. Known issues and difficult areas
   For each known issue, state the source, why it matters to the interview, neutral questions to ask, and the evidence needed to test the answer.

5. Closing questions and actions
   Include questions about additional documents, communications, calendars, devices, people with relevant knowledge, corrections to the account and follow-up needed.

For every factual proposition, cite the supplied source by document ID and page/paragraph, or pleading name and paragraph. Label unverified points as "To verify". If sources conflict, set out each account without choosing between them. Do not invent facts, dates, document contents, legal tests or witness answers.
2Turn a chronology into questionsUse this when the case chronology exists but you need a practical sequence of questions for one witness.
Convert the chronology below into an interview question plan for [witness name] in [matter name]. This is a draft for qualified review, not legal advice.

Witness role and likely involvement: [paste]
Chronology: [paste, including event date, event description, source document ID and page/paragraph]
Pleadings relevant to this witness: [paste with paragraph references]
Known issues: [paste]

Produce these sections:

1. Chronology gaps
   Make a table: Date/event; source; what is established by the source; what remains unclear; whether [witness name] may be able to address it; question priority.

2. Interview questions by event
   For each event, use this format:
   - Event and date:
   - Documents to have available:
   - Objective:
   - Open account questions:
   - Document-specific follow-up questions:
   - Questions testing timing, participants, communications and decisions:
   - Questions separating direct knowledge from hearsay:
   - Follow-up evidence to request:

3. Cross-event consistency checks
   List questions that test changes in the witness's account, missing time periods, inconsistent dates, unexplained communications and differences between the pleadings and documents.

4. Points not to assume
   List facts that appear in only one source, facts stated without a source, and unclear document provenance.

Cite every question set to the relevant chronology entry, pleading paragraph or document ID and page/paragraph. Keep questions neutral and short. Where a date, identity, document reference or event is ambiguous, write "Clarify before interview" and state precisely what is missing. Do not resolve inconsistencies or add facts.
3Prepare document-led interview questionsUse this when the witness needs to be taken through emails, notes, messages, meeting records or other key documents.
Prepare a document-led interview plan for [witness name] concerning the documents below in [matter name]. This is a drafting work product for review by a qualified person, not legal advice.

Witness background: [paste]
Issues in the pleadings: [paste with paragraph references]
Documents: [paste each document with ID, date, type, author, recipient, page/paragraph, and text or summary]
Known concerns about authenticity, completeness or provenance: [paste]

Return:

1. Document order
   Provide a table with columns: Order; document ID; date; event/topic; reason to use it; whether to show early, after an open account, or only if needed.
   Put documents in a sequence that first obtains the witness's own account, then tests it against the record.

2. Questions for each document
   For every document, provide:
   - Source reference
   - Purpose of the questions
   - Open questions before showing the document
   - Questions on authorship, receipt, attachments, copying, forwarding, editing, filing and retention
   - Questions on the meaning of material wording, participants, timing and action taken
   - Questions on missing surrounding communications or drafts
   - Follow-up documents or people to identify

3. Document conflicts
   Make a table: Document ID; conflicting source; nature of conflict; neutral question; information needed to resolve it.

4. Handling notes
   Identify documents that may be incomplete, wrongly dated, duplicated, difficult to read or attributed to an uncertain author. State the exact verification needed.

Use only the supplied material. Cite every item by document ID and page/paragraph. Do not state that a document proves a fact. Say what it appears to record and what the witness should be asked to explain. If a document is missing or its text is not supplied, do not summarise it.
4Test inconsistencies and evidence gapsUse this after an initial plan when the team needs to identify what could undermine, qualify or complicate the witness account.
Review the materials below for inconsistencies, evidence gaps and interview priorities concerning [witness name] in [matter name]. This is a draft for qualified review, not legal advice.

Pleadings: [paste with paragraph references]
Witness account or prior note: [paste with source reference]
Document bundle or evidence index: [paste with document IDs, dates and page/paragraph references]
Known issues: [paste]

Return four sections.

1. Issue matrix
   Use a table with columns: Issue; pleading position; witness account; supporting documents; contrary documents; gap or inconsistency; interview question; source references; priority.

2. Questions to test the account
   Group questions by event. For each question, state whether it tests memory, timing, direct knowledge, document provenance, communications, decision-making, completeness or consistency. Start with an open question, then give any necessary focused follow-up.

3. Evidence to obtain or preserve
   List each missing item with: item or source; likely custodian; date range; reason it may assist; link to the relevant issue; whether the need is confirmed or tentative.

4. Ambiguities requiring instructions
   List each ambiguity, the competing readings, the source references and the instruction needed before the interview plan can be finalised.

Do not rank evidence as true or false. Do not make findings of fact. Do not assume that absence from the supplied bundle means a document does not exist. Quote only short extracts where needed to identify the point, and give the exact source reference for each extract.
5Run the pre-interview quality checkUse this immediately before the interview to check that the plan can be used, sourced and updated during the meeting.
Quality-check this draft interview plan for [witness name] in [matter name]. This is a drafting work product for review by a qualified person, not legal advice.

Draft plan: [paste]
Pleadings: [paste or paste a list of relevant pleading paragraphs]
Evidence index: [paste with document IDs, dates and page/paragraph references]
Known issues and interview objectives: [paste]

Return:

1. Readiness checklist
   Use a table with columns: Check; status (ready / needs work / cannot verify); explanation; required action.
   Check whether every material question is linked to an event, pleading paragraph, document or stated interview objective; whether questions are grouped by event and document; whether the plan distinguishes known facts from matters to verify; whether source references are usable; and whether the closing questions seek missing documents and relevant people.

2. Missing or weak questions
   List each gap under these headings: witness role; chronology; documents; communications; decisions; direct knowledge; contradictory material; missing evidence; known issues; closing actions.
   For each gap, provide a replacement or additional question and state where it belongs in the plan.

3. Unsafe assumptions or wording
   Identify leading, compound, vague or unsupported questions. Rewrite each as a neutral, single-purpose question. Identify assertions that lack a source and mark them "To verify".

4. Interviewer run sheet
   Provide a concise ordered list: opening topics; event blocks; documents to use; issues to revisit; requests for follow-up material; closing questions. Preserve all source references.

Do not add facts from general knowledge. If a cited document, pleading paragraph or date cannot be located in the supplied material, mark it "Reference not verified" and state what must be checked.

Last checked against xAI’s own pages on 2026-08-21. Grok changes quickly; anything version-specific should be confirmed upstream before you rely on it.

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