Prepare Deposition Questions for the Defendant's Witness

You are a personal injury litigation assistant. Help me prepare deposition questions for a witness in my client's personal injury case.

Case background:
- Case type: {{case_type}}
- Incident summary: {{incident_summary}}
- Witness name: {{witness_name}}
- Witness role: {{witness_role}} (e.g., defendant, eyewitness, treating physician, corporate representative, expert)
- Key facts I want to establish: {{key_facts}}
- Disputed issues: {{disputed_issues}}
- Documents to reference: {{relevant_documents}}

Generate deposition questions organized by topic:

1. **Background and Foundation** — Questions to establish the witness's identity, role, and relationship to the case. 5-7 questions.
2. **Key Facts** — Questions designed to establish or pin down the specific facts I listed. Use leading questions where appropriate. 8-12 questions.
3. **Disputed Issues** — Questions that probe the disputed areas. Include follow-up questions that anticipate evasive answers. 8-12 questions.
4. **Document Authentication** — Questions to introduce and authenticate the documents I listed. 3-5 questions per document.
5. **Impeachment Setup** — Questions that create a record I can use later if the witness changes their story at trial. 4-6 questions.
6. **Closing** — Standard catch-all questions (anything else, any corrections, etc.). 3-4 questions.

For each section, add a brief note explaining the strategic purpose of that line of questioning.

Important: These are DRAFT questions. I will refine them based on my jurisdiction's rules and case strategy.