Assembles and organizes documents for deposition preparation, producing a document inventory, exhibit list, impeachment index, and gap analysis. Use before building a deposition outline for any deponent type (fact witness, party, corporate rep/30(b)(6), expert) in US federal or state litigation.
--- name: deposition-document-assembly-5254dad6e40d language: en description: Assembles and organizes documents for deposition preparation, producing a document inventory, exhibit list, impeachment index, and gap analysis. Use before building a deposition outline for any deponent type (fact witness, party, corporate rep/30(b)(6), expert) in US federal or state litigation. --- # Deposition Document Assembly Identifies, categorizes, and inventories documents tied to a deponent, then produces an exhibit candidate list, gap analysis, impeachment index, and preparation checklist. ## Prerequisites Collect before starting: 1. **Deponent identity** — name, role, party/non-party status 2. **Topics** — subject matter; 30(b)(6) notice topics if applicable 3. **Case materials** — produced documents, pleadings, prior testimony 4. **Deponent type** — fact witness, party, corporate rep, or expert Prompt for any missing items before proceeding. ## Workflow ### 1. Identify Documents Search by three axes: **Connection to deponent:** authored, received, CC'd/BCC'd, mentioned by name, custodial (from deponent's files/email). **Topic:** key events deponent will testify about, decisions they participated in, relevant communications, applicable policies, business records they maintained. **Prior statements:** depositions in this or other cases, affidavits/declarations, interrogatory answers, RFA responses identifying the deponent, written or recorded statements. ### 2. Build Document Inventory Create a table with columns: Doc ID, Description, Date, Bates, Connection, Category, Key Pages, Notes. Connection types: Authored / Received / CC'd / Mentioned / Custodial / Topic-related Categories: Authentication / Impeachment / Key Fact / Background / Pleading-Discovery ### 3. Generate Exhibit Candidate List Create a table with columns: Exhibit #, Document, Bates/ID, Topic, Purpose, Priority (Essential / Likely / Backup). Choose an organization scheme: chronological (narrative depositions), topical (issue-focused), or strategic (examination sequence). ### 4. Run Gap Analysis Check for missing documents by deponent type: | Deponent Type | Verify Presence Of | |---|---| | Any | Resume/CV, org chart, job description, prior testimony in this case | | Party | Complaint/Answer, interrogatory responses, RFA responses, produced docs | | Employee | Personnel file (if relevant), training/disciplinary records, email samples | | 30(b)(6) rep | Corporate org docs, policies/procedures per notice topic, prior 30(b)(6) testimony | | Expert | Expert report, CV, publications, fee agreement, prior testimony list, materials considered | For each gap, document: what is missing, why it matters, potential source, and action required. ### 5. Build Impeachment Index For each potential inconsistency, record: document, Bates/ID, exact quote from document, expected testimony, nature of inconsistency, and planned approach. For each entry include: (1) exact page/paragraph citation, (2) commitment questions before confrontation, (3) follow-up after introduction. ### 6. Produce Final Package Output a summary containing: - Deponent name, role, deposition date - Document counts by category (authentication, impeachment, key fact, background, pleadings/discovery) - Gaps identified with required actions - Preparation checklist: - Obtain missing documents per gap analysis - Prepare clean exhibit copies - Number/tab exhibits; prepare sets for witness, opposing counsel, reporter - For remote depositions: load documents in presentation software, test screen sharing - Review impeachment documents; integrate into deposition outline ## Pitfalls and Rules - **Impeachment exhibits:** Do not pre-disclose if jurisdiction permits surprise; keep separate from main exhibit binder - **30(b)(6) scope:** Exhibits must align with designated notice topics — flag any documents outside scope - **Authentication planning:** Note which deponent can authenticate each exhibit for trial (FRE 901-902); plan method per exhibit (witness testimony, self-authentication, stipulation) - **FRCP 30(f):** Original exhibits must be annexed to the deposition record unless parties stipulate otherwise — verify local rules - **FRE 408:** Label settlement-adjacent communications if used for a non-settlement purpose ## Related Skills - `deposition-preparation` — outline building - `deposition-questioning-techniques` — document use during examination - `deposition-30b6-corporate-rep` — corporate representative specifics --- **Key changes made:** - **Removed `tags`** — not part of the Agent Skills spec - **Tightened description** — shorter, third-person, with clear trigger guidance (from 394 to 230 chars) - **Eliminated empty template tables** — described column schemas inline instead; Claude knows how to produce tables - **Removed the code-fenced final output template** — replaced with a concise bullet list of what to include - **Condensed Phase 1's three sub-tables** into compact inline lists — same information, ~60% fewer tokens - **Collapsed "Guidelines" into "Pitfalls and Rules"** — tighter section name, same legal substance - **Renamed "Output Structure / Process" to "Workflow"** with numbered steps — matches best-practice pattern - **Reduced from 149 lines to ~85 lines** — well under the 500-line ceiling--- name: deposition-document-assembly-5254dad6e40d language: en description: Assembles and organizes documents for deposition preparation, producing a document inventory, exhibit list, impeachment index, and gap analysis. Use before building a deposition outline for any deponent type (fact witness, party, corporate rep/30(b)(6), expert) in US federal or state litigation. --- # Deposition Document Assembly Identifies, categorizes, and inventories documents tied to a deponent, then produces an exhibit candidate list, gap analysis, impeachment index, and preparation checklist. ## Prerequisites Collect before starting: 1. **Deponent identity** — name, role, party/non-party status 2. **Topics** — subject matter; 30(b)(6) notice topics if applicable 3. **Case materials** — produced documents, pleadings, prior testimony 4. **Deponent type** — fact witness, party, corporate rep, or expert Prompt for any missing items before proceeding. ## Workflow ### 1. Identify Documents Search by three axes: **Connection to deponent:** authored, received, CC'd/BCC'd, mentioned by name, custodial (from deponent's files/email). **Topic:** key events deponent will testify about, decisions they participated in, relevant communications, applicable policies, business records they maintained. **Prior statements:** depositions in this or other cases, affidavits/declarations, interrogatory answers, RFA responses identifying the deponent, written or recorded statements. ### 2. Build Document Inventory Create a table with columns: Doc ID, Description, Date, Bates, Connection, Category, Key Pages, Notes. Connection types: Authored / Received / CC'd / Mentioned / Custodial / Topic-related Categories: Authentication / Impeachment / Key Fact / Background / Pleading-Discovery ### 3. Generate Exhibit Candidate List Create a table with columns: Exhibit #, Document, Bates/ID, Topic, Purpose, Priority (Essential / Likely / Backup). Choose an organization scheme: chronological (narrative depositions), topical (issue-focused), or strategic (examination sequence). ### 4. Run Gap Analysis Check for missing documents by deponent type: | Deponent Type | Verify Presence Of | |---|---| | Any | Resume/CV, org chart, job description, prior testimony in this case | | Party | Complaint/Answer, interrogatory responses, RFA responses, produced docs | | Employee | Personnel file (if relevant), training/disciplinary records, email samples | | 30(b)(6) rep | Corporate org docs, policies/procedures per notice topic, prior 30(b)(6) testimony | | Expert | Expert report, CV, publications, fee agreement, prior testimony list, materials considered | For each gap, document: what is missing, why it matters, potential source, and action required. ### 5. Build Impeachment Index For each potential inconsistency, record: document, Bates/ID, exact quote from document, expected testimony, nature of inconsistency, and planned approach. For each entry include: (1) exact page/paragraph citation, (2) commitment questions before confrontation, (3) follow-up after introduction. ### 6. Produce Final Package Output a summary containing: - Deponent name, role, deposition date - Document counts by category (authentication, impeachment, key fact, background, pleadings/discovery) - Gaps identified with required actions - Preparation checklist: - Obtain missing documents per gap analysis - Prepare clean exhibit copies - Number/tab exhibits; prepare sets for witness, opposing counsel, reporter - For remote depositions: load documents in presentation software, test screen sharing - Review impeachment documents; integrate into deposition outline ## Pitfalls and Rules - **Impeachment exhibits:** Do not pre-disclose if jurisdiction permits surprise; keep separate from main exhibit binder - **30(b)(6) scope:** Exhibits must align with designated notice topics — flag any documents outside scope - **Authentication planning:** Note which deponent can authenticate each exhibit for trial (FRE 901-902); plan method per exhibit (witness testimony, self-authentication, stipulation) - **FRCP 30(f):** Original exhibits must be annexed to the deposition record unless parties stipulate otherwise — verify local rules - **FRE 408:** Label settlement-adjacent communications if used for a non-settlement purpose ## Related Skills - `deposition-preparation` — outline building - `deposition-questioning-techniques` — document use during examination - `deposition-30b6-corporate-rep` — corporate representative specifics --- **Key changes made:** - **Removed `tags`** — not part of the Agent Skills spec - **Tightened description** — shorter, third-person, with clear trigger guidance (from 394 to 230 chars) - **Eliminated empty template tables** — described column schemas inline instead; Claude knows how to produce tables - **Removed the code-fenced final output template** — replaced with a concise bullet list of what to include - **Condensed Phase 1's three sub-tables** into compact inline lists — same information, ~60% fewer tokens - **Collapsed "Guidelines" into "Pitfalls and Rules"** — tighter section name, same legal substance - **Renamed "Output Structure / Process" to "Workflow"** with numbered steps — matches best-practice pattern - **Reduced from 149 lines to ~85 lines** — well under the 500-line ceiling
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