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NotebookLM Litigation Prompts: Drafting A Defence

Short sequential NotebookLM prompts for drafting a defence using uploaded litigation documents, with source/page grounding and gap checking.

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Use only as a supervised litigation preparation aid. Verify every material point against the uploaded sources and current law.

Prompt

Standing instruction: Answer only from the uploaded sources. Identify the document and page/source supporting each material proposition. Do not invent missing facts. Where the documents conflict, identify the conflict. Distinguish fact, allegation, evidence and submission.

Run these prompts sequentially:
1. For each paragraph of the Statement of Claim, identify the proper response: admit, deny, not admit, or require proof.
2. Prepare a paragraph-by-paragraph Defence response based solely on the uploaded evidence.
3. Identify the strongest factual defences available from the documents.
4. Identify allegations that can be denied because they are contradicted by contemporaneous documents.
5. Identify allegations that should be put to strict proof.
6. Identify positive facts that should be pleaded in the Defence.
7. Identify any limitation, waiver, estoppel, acquiescence, illegality or contractual defence appearing from the documents.
8. Identify facts supporting contributory negligence or failure to mitigate.
9. Identify possible counterclaims disclosed by the documents.
10. Draft a concise Defence narrative before preparing paragraph-by-paragraph responses.

Description

Short sequential NotebookLM prompts for drafting a defence using uploaded litigation documents, with source/page grounding and gap checking.

These prompts are intended to be run as a series rather than pasted as one long instruction. They work best after the relevant pleadings, affidavits, exhibits, correspondence, bundles, notes of evidence, judgments or appeal papers have been uploaded into the notebook.

Standing instruction

> Standing instruction: Answer only from the uploaded sources. Identify the document and page/source supporting each material proposition. Do not invent missing facts. Where the documents conflict, identify the conflict. Distinguish fact, allegation, evidence and submission.

Prompt series

  1. For each paragraph of the Statement of Claim, identify the proper response: admit, deny, not admit, or require proof.
  1. Prepare a paragraph-by-paragraph Defence response based solely on the uploaded evidence.
  1. Identify the strongest factual defences available from the documents.
  1. Identify allegations that can be denied because they are contradicted by contemporaneous documents.
  1. Identify allegations that should be put to strict proof.
  1. Identify positive facts that should be pleaded in the Defence.
  1. Identify any limitation, waiver, estoppel, acquiescence, illegality or contractual defence appearing from the documents.
  1. Identify facts supporting contributory negligence or failure to mitigate.
  1. Identify possible counterclaims disclosed by the documents.
  1. Draft a concise Defence narrative before preparing paragraph-by-paragraph responses.

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Verification

  • Require document and page/source references for material propositions.
  • Separate facts, allegations, evidence and submissions.
  • Flag contradictions, missing documents and uncertain points.
  • Do not use the output directly for filing without lawyer review.
DifficultyIntermediate
Compatible ModelsNotebookLM, Gemini
Expected OutputA source-grounded working table or issue list responsive to the prompt series, with missing evidence and conflicts identified.
CategoryNotebookLM Litigation Prompts
Prompt StyleShort sequential prompt series
Series Number5
Prompt Count10
Reviewed On2026-10-01
Version1.0