# Topic block library

Last updated: 2026-08-19

The question modules the skill draws from. Each block states its purpose and the reason its questions are phrased as they are. Adapt the wording to your jurisdiction and practice — the block structure and ordering are what the skill relies on.

Ordering is fixed: base blocks 1 and 2, then substantive blocks in chronological order, then admissions, then impeachment. Role modules add blocks inside the substantive range.

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## Base block 1 — Background and foundation

Purpose: establish the witness's role, reporting line, and the boundaries of what they can speak to. Runs on every deponent.

- What was your title during [relevant period]? Did it change?
- Who did you report to? Who reported to you?
- Which of your responsibilities touched [subject matter]?
- What systems did you use for [subject matter] — name each one.
- Who else at [organization] worked on [subject matter] with you?

*Why phrased this way:* each question is a single fact with no compound clause. Compound questions invite a "vague and ambiguous" objection and give the witness a choice of which half to answer.

## Base block 2 — Document authenticity and record-keeping

Purpose: establish that the exhibits are what they appear to be, before you spend substantive time on them.

- Do you recognize Exhibit [n]? [cite]
- Did you prepare it, receive it, or both?
- Was it kept in the ordinary course of [organization]'s business?
- Was it your practice to [send / retain / update] documents of this kind?
- Is there anything on the face of it you do not recognize?

*Why early:* an exhibit the witness will not authenticate changes which substantive questions are worth asking. Discovering that in hour five wastes the questions built on it.

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## Role modules

### `executive`

- Which decisions in this area required your approval?
- What did you rely on when you approved [decision]?
- Who briefed you, and how often?
- What would have caused you to decide differently?

### `custodian_of_records`

- How is [record type] created, and by whom?
- Where is it stored, and for how long?
- What is the retention schedule, and who administers it?
- What would a complete production of [record type] contain?

### `finance`

- Which figures in [document] did you produce, and from which source system?
- What assumptions sit behind [figure]?
- Who reviewed the figure before it was circulated?
- Was [figure] ever restated or corrected?

### `engineering`

- What did [system / feature] actually do during [period]?
- Where is that behavior documented, and does the documentation match?
- What logs or version history exist for [period]?
- Who could change [component], and was the change reviewed?

### `sales`

- What were you told to represent to customers about [subject]?
- What did you actually say to [customer]?
- Where is that recorded — CRM notes, email, call recording?
- What did you do when a customer asked about [known limitation]?

### `hr`

- What did the complaint process require at the time?
- What steps were taken here, and when?
- Where is each step documented?
- Who decided the outcome?

### `third_party`

- What is your relationship to [party]?
- What were you asked to do, and by whom?
- What did you produce or deliver, and to whom?
- What did you keep?

### `expert`

- What materials did you rely on? Which did you review but not rely on?
- What did you not have access to?
- What would change your opinion?
- Which of your assumptions were supplied by counsel rather than derived?

### `rule_30b6_designee`

- Which noticed matters were you designated for?
- What did you do to prepare on matter [n]?
- Whom did you speak with, and what did you review?
- On matter [n], is that the organization's position?

*Why the preparation questions come first:* a designee testifies to information known or reasonably available to the organization, so what they did to prepare is itself a substantive line.

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## Admissions block

Purpose: capture concessions while the examination is still cooperative — before any impeachment.

Format each admission as: the proposition sought, the supporting cite, and a fallback line if the witness denies it.

- Ask for one fact per admission. A compound admission is a denied admission.
- Draft the fallback before the deposition, not during it. The fallback is usually a foundation walk: distribution list, calendar entry, system access log.
- Do not ask the witness to agree with a characterization ("that was reckless"). Ask for the fact and argue the characterization later.

## Impeachment block

Purpose: put prior inconsistent statements on the record in an admissible sequence. See `3-impeachment-pair-worksheet.md` for the pair format — do not draft impeachment questions in any other shape.