---
name: deposition-outline
description: Build a deposition outline from an indexed record. Given a Bates-indexed record index, the deponent's role, and the examination goals, the skill outputs a chronology, topic blocks with per-question record cites, a list of admissions to lock in, and impeachment pairs built from the deponent's own prior inconsistent statements — plus a time budget against the seven-hour clock and a coverage report naming what the outline does not reach. Use after the record is assembled and before the examining attorney drafts questions.
---
# Deposition outline from the record
## When to invoke
Invoke once per deponent, after the relevant record has been assembled and indexed, and before the examining attorney starts drafting.
Typical callers:
- Litigation-support or legal-ops staff preparing outline drafts for an examining attorney
- Associates working a witness whose prior statements are spread across several productions and transcripts
- Inside counsel preparing a Rule 30(b)(6) examination against a noticed matters list
Do NOT invoke this skill for:
- **Deciding whom to depose, or in what order.** Witness sequencing is a strategic judgment tied to a defense or case theory. This skill drafts an outline for a deponent who has already been noticed.
- **Drafting a case theory, a defense narrative, or a strategy memo.** Those are work product. This skill produces an examination outline built from cited record material.
- **Producing the certified deposition record.** The outline is preparation. Nothing here substitutes for the transcript, the errata process, or Rule 32 designations.
- **Any run where the record index is not cite-resolved.** If exhibit and transcript references have not been reduced to a Bates-numbered or otherwise stable index, stop. See the fabrication guard below.
- **Auto-serving anything.** The skill drafts; the examining attorney edits, and counsel owns every question that reaches the record.
## Inputs
- Required: `record_index` — path to, or inline text of, a completed `references/2-record-index-template.md`. Each row carries a stable identifier (Bates range, transcript page:line, or production document ID), a date, a source, a one-line description, and a `privileged` flag. The skill reads cites **only** from this file.
- Required: `deponent` — object with `name`, `title`, and `role` (one of `executive | custodian_of_records | finance | engineering | sales | hr | third_party | expert | rule_30b6_designee`). Drives which topic-block modules load.
- Required: `examination_goals` — 3 to 8 plain-language goals, in priority order (for example: "establish he approved the pricing change before the March board meeting").
- Optional: `noticed_matters` — required when `role` is `rule_30b6_designee`: the numbered matters for examination from the Rule 30(b)(6) notice. Blocks are tagged to matter numbers; anything untagged is moved to a "beyond the notice" appendix.
- Optional: `time_budget_minutes` — defaults to `330`. See the seven-hour clock below.
- Optional: `prior_statement_sources` — subset of `record_index` rows that contain the deponent's own statements (declarations, prior transcripts, emails they authored, interrogatory verifications). If omitted, the skill infers them from the `author` column and reports what it inferred.
## Reference files
Loaded from `references/` at run time:
- `references/1-topic-block-library.md` — the question modules, organized by block type and deponent role, each with a stated purpose and the reason the question is phrased the way it is.
- `references/2-record-index-template.md` — the fillable record index. This is the primary adaptation point and the only source of cites.
- `references/3-impeachment-pair-worksheet.md` — the confront-then-introduce pair format, plus the pre-deposition checklist the examining attorney completes before the outline is used.
## Method
Two passes, in this order. The separation is load-bearing, not stylistic.
**Pass 1 — build the statement inventory.** The skill reads `record_index` and produces two intermediate artifacts: a dated chronology of events, and an inventory of the deponent's own statements, each row carrying its identifier verbatim from the index. Nothing is drafted in this pass. If a required index column is missing, or if fewer than three rows resolve to the deponent, the skill emits a structured error and stops rather than proceeding on a thin record.
*Why two passes:* the drafting pass may reference only rows that exist in the inventory built by pass one. A question cannot cite a document the extraction step did not find, because the drafting step never sees the raw record — it sees the inventory. This is the structural guard against invented exhibit numbers, and it is the reason a single-pass "read the documents and write questions" prompt is the wrong shape for this job.
**Pass 2 — assemble topic blocks in a fixed order.** Blocks are emitted as: background and foundation; document authenticity and record-keeping; substantive topics in chronological order; admissions to lock in; impeachment pairs.
*Why this order:* admissions come before impeachment. A witness who has been confronted with a prior inconsistent statement becomes guarded and stops conceding, so every concession you want on the record is asked for while the examination is still cooperative. Authenticity comes early because an exhibit the witness will not authenticate changes which substantive questions are worth asking.
**Time budget against the seven-hour clock.** Federal depositions are limited to one day of seven hours under Rule 30(d)(1) absent stipulation or court order. The skill assigns a minute estimate per block and defaults the budget to 330 minutes of question time, holding roughly 90 minutes back for objections, exhibit handling, colloquy, and breaks. When the assembled outline exceeds the budget, the skill does not silently trim: it emits the full outline and a ranked cut list showing which blocks to drop first, ordered by the lowest-priority `examination_goals` they serve.
**Impeachment pairs are sequenced, not just listed.** Each pair is emitted in three steps — lock the current testimony, confront with the prior statement, then introduce. Rule 613(b), as amended effective 1 December 2024, provides that extrinsic evidence of a prior inconsistent statement may not be admitted until the witness has had an opportunity to explain or deny it and an adverse party has had an opportunity to examine on it. The pair template puts the confrontation step ahead of the introduction step so the outline cannot be worked in an order that forfeits the impeachment.
**Coverage report.** The last section lists every `record_index` row that no question cites, every `examination_goals` entry that no block serves, and every block that carries no exhibit. This is the section the examining attorney reads first.
## Output format
The skill emits one Markdown document with this literal structure:
```markdown
# Deposition outline — Dana Reyes (VP Finance)
Matter: Northgate v. Arbor Systems | Prepared: 2026-08-19
Record index: 214 rows, production through ARB-0041882 (2026-07-30)
Estimated question time: 288 min of 330 budgeted
## Chronology
| Date | Event | Cite |
|---|---|---|
| 2026-01-14 | Reyes circulates draft margin model | ARB-0011204 |
| 2026-03-02 | Board deck states margin floor of 18% | ARB-0018331 |
## Block 1 — Background and foundation (18 min)
Purpose: establish role, reporting line, and document-handling practice.
1. What was your title in January 2026?
2. Who did you report to? [follow-up: any change during the relevant period?]
3. Did you review the margin model before it went to the board? [ARB-0011204]
## Block 4 — Pricing approval (52 min) [goal 1, goal 3]
1. Exhibit 12 is the 2 March board deck. Do you recognize it? [ARB-0018331]
2. Did you prepare the margin figure on slide 9? [ARB-0018331]
[PRIVILEGE-CHECK: index row ARB-0018340 is flagged privileged — do not
examine on the counsel memo attached to this deck]
## Admissions to lock in
| # | Admission sought | Supporting cite | Fallback if denied |
|---|---|---|---|
| A1 | She saw the 18% floor before 2 March | ARB-0018331 | Walk the distribution list |
## Impeachment pairs
### IP-1 — Timing of first knowledge
1. LOCK: "So you first saw the margin floor in April?"
2. CONFRONT: "Do you recall testifying on 12 May 2026 that you saw it in
February?" [Reyes Dep. 88:4-88:19]
3. INTRODUCE: offer Reyes Dep. 88:4-88:19 only after step 2 is answered.
## Coverage report
- Uncited index rows: 31 of 214 (list follows)
- Goals with no block: none
- Blocks without an exhibit: Block 1
- [UNCITED] questions: 2 (Block 6, questions 4 and 7)
```
Any question the skill wants to ask but cannot tie to an index row is emitted with an `[UNCITED]` marker and counted in the coverage report. It is never dropped silently and never given a plausible-looking cite.
## Watch-outs
- **Fabricated record cites.** A model asked to write questions about documents will invent document numbers that look correct. Guard: cites are copied verbatim from `record_index` rows and never composed; any question whose cite does not resolve to an index row is emitted as `[UNCITED]` and counted in the coverage report. Verify a sample against the production before the outline is used — as of 19 August 2026 the AI Hallucination Cases database lists 1,933 decisions worldwide, 1,324 of them in the United States, in which a court found a party relied on hallucinated material.
- **Impeachment sequenced wrongly.** Introducing the prior statement before confronting the witness forfeits the impeachment under amended Rule 613(b). Guard: pairs are emitted only in the lock/confront/introduce format from `references/3-impeachment-pair-worksheet.md`, and the introduce step carries an explicit "only after step 2 is answered" instruction.
- **Running past the clock.** Outlines drafted without a time model routinely overrun the seven hours in Rule 30(d)(1), and the topics that get cut are whichever ones happened to be last. Guard: per-block minute estimates, a 330-minute default budget, and a ranked cut list tied to goal priority rather than block order.
- **Privileged material pulled into the examination.** A record index assembled from a production can include clawed-back or inadvertently produced material. Guard: rows flagged `privileged` in the index are excluded from question generation, and any block touching a document adjacent to a flagged row carries a `[PRIVILEGE-CHECK]` annotation naming the row.
- **Rule 30(b)(6) topic drift.** Questions outside the noticed matters can be refused by the designee and invite a protective-order fight mid-deposition. Guard: when `noticed_matters` is supplied, every block is tagged with the matter numbers it serves and untagged blocks are moved to a "beyond the notice" appendix rather than folded into the main outline.
- **A record index that predates a rolling production.** Guard: the index header carries `production_through` (Bates range and date). The skill prints it in the outline header and emits a warning when that date is more than 14 days before the run date, so the drafter knows to re-index before the deposition.
- **Instructions not to answer treated as an obstacle to route around.** Rule 30(c)(2) permits an instruction not to answer only to preserve a privilege, to enforce a court-ordered limitation, or to present a Rule 30(d)(3) motion. Guard: the outline does not draft workaround questions for anticipated instructions; it flags the block and leaves the response to counsel on the record.
# 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.
---
## 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.
---
## 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.
---
## 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.
# Record index template
Fill this in once per deponent. **This file is the only source of cites the skill will use.** A row that is not here cannot be cited by any question, and a cite that is not copied from a row here is treated as a fabrication and marked `[UNCITED]`.
Replace the sample rows below with your own.
---
## Header
```yaml
matter: Northgate v. Arbor Systems
matter_number: 3:26-cv-00841
deponent: Dana Reyes
deponent_title: VP Finance
deposition_date: 2026-09-11
production_through: ARB-0041882
production_through_date: 2026-07-30
transcripts_included:
- Reyes Dep. (2026-05-12), pages 1-214
- Okonjo Dep. (2026-06-03), pages 1-176
```
`production_through` and `production_through_date` are not optional. The skill prints them in the outline header and warns when the date is more than 14 days before the run date, because a rolling production makes a stale index the most common source of a wrong cite.
## Rows
| id | date | source | author | description | privileged | deponent_statement |
|---|---|---|---|---|---|---|
| ARB-0011204 | 2026-01-14 | email + attachment | D. Reyes | Draft margin model circulated to finance leads | no | yes |
| ARB-0018331 | 2026-03-02 | board deck | M. Okonjo | Q1 board deck, slide 9 states 18% margin floor | no | no |
| ARB-0018340 | 2026-03-02 | memo | outside counsel | Attached counsel memo — clawed back 2026-06-18 | yes | no |
| ARB-0022917 | 2026-04-07 | Slack export | D. Reyes | "I hadn't seen the floor until this week" | no | yes |
| Reyes Dep. 88:4-88:19 | 2026-05-12 | transcript | D. Reyes | Testifies she saw the floor in February | no | yes |
### Column rules
- **`id`** — a stable identifier: a Bates number or range, a `Transcript page:line` reference, or a production document ID. Never a filename, a folder path, or a description. This string is copied verbatim into every question that cites the row.
- **`date`** — the date of the document, not the date of production. Drives the chronology.
- **`source`** — the document type. Used to select authenticity questions in base block 2.
- **`author`** — who created or sent it. When `prior_statement_sources` is omitted, the skill infers the deponent's own statements from this column and reports what it inferred.
- **`description`** — one line, factual. Do not editorialize here; characterizations in the index end up in questions.
- **`privileged`** — `yes` for anything clawed back, withheld, or logged. Rows marked `yes` are excluded from question generation, and adjacent rows draw a `[PRIVILEGE-CHECK]` annotation.
- **`deponent_statement`** — `yes` when the row contains a statement by the deponent. These rows are the raw material for the impeachment block. If fewer than three rows across the index resolve to the deponent, the skill stops rather than drafting impeachment from a thin record.
### Size guidance
A useful index for a single fact witness runs 80 to 400 rows. Below about 50, you are usually indexing a subset and will get a coverage report full of gaps you cannot explain. Above about 800, split by topic and run the skill once per topic — a single oversized index dilutes the chronology and makes the time budget meaningless.
## Noticed matters (Rule 30(b)(6) only)
Required when the deponent role is `rule_30b6_designee`. Copy the numbered matters from the notice verbatim.
```yaml
noticed_matters:
- number: 1
text: The organization's pricing approval process from 2025-06-01 to present
- number: 4
text: The organization's document retention practices for board materials
```
Blocks are tagged with the matter numbers they serve. Anything untagged is moved to a "beyond the notice" appendix — not deleted, but not mixed into the main outline either.
# Impeachment pair worksheet
Every impeachment in the outline is emitted as a three-step pair. Do not draft impeachment questions in any other shape, and do not reorder the steps.
## Why the sequence is fixed
Rule 613(b) of the Federal Rules of Evidence, as amended effective 1 December 2024, provides that extrinsic evidence of a witness's prior inconsistent statement may not be admitted until after the witness is given an opportunity to explain or deny the statement and an adverse party is given an opportunity to examine the witness about it, unless the court orders otherwise. The pre-amendment rule imposed no sequence. The amended rule does, so an outline that lists "impeach with Exhibit 14" without a confrontation step ahead of it is an outline that can be worked in an order that forfeits the impeachment.
Rule 613(a) is the reason the confront step is phrased as a question rather than a document hand-up: when examining a witness about a prior statement you need not show it or disclose its contents to the witness, though you must show or disclose it to opposing counsel on request. Asking first and showing second is what preserves the value of the inconsistency.
Check your jurisdiction. Several states have not adopted the 2024 federal sequence, and some impose a stricter foundation (time, place, and persons present) than the federal rule.
## The pair format
```
### IP-[n] — [one-line label for the inconsistency]
Goal served: [goal number from examination_goals]
1. LOCK: [question that pins the witness to the current version]
Follow-up if hedged: [narrowing question]
2. CONFRONT: [question naming the prior statement, its date, and its setting]
[cite — copied verbatim from the record index]
3. INTRODUCE: offer [cite] only after step 2 is answered.
If the witness adopts the prior statement: stop — you have the testimony,
do not introduce.
If the witness denies making it: [foundation line — authorship, signature,
verification, or transcript certification]
```
## Worked example
```
### IP-1 — Timing of first knowledge of the margin floor
Goal served: goal 1
1. LOCK: "So the first time you saw the 18% margin floor was in April?"
Follow-up if hedged: "Before this lawsuit, had you seen it at any point
in the first quarter?"
2. CONFRONT: "Do you recall testifying under oath on 12 May 2026 that you
saw the floor in February?" [Reyes Dep. 88:4-88:19]
3. INTRODUCE: offer Reyes Dep. 88:4-88:19 only after step 2 is answered.
If the witness adopts it: stop.
If the witness denies it: "That transcript carries the reporter's
certification and you signed the errata on 2 June — correct?"
```
## Drafting rules
- **One inconsistency per pair.** Two inconsistencies in one pair means the witness answers the weaker one.
- **The LOCK question must be answerable yes or no.** An open lock question gives the witness room to pre-empt the confrontation.
- **Name the date and setting in the CONFRONT step.** "You said something different before" is not a confrontation; "you testified on 12 May" is.
- **Write the denial branch before the deposition.** Improvising a foundation for a denied prior statement is where impeachments are lost.
- **Order pairs weakest to strongest** when you have several for one witness. The first impeachment is what makes the witness guarded; spend it on the pair you can most afford to lose.
## Pre-deposition checklist
Complete this before the outline is used. Initial each line.
- [ ] Every cite in the impeachment block resolves to a document in the production or a certified transcript page — checked against the source, not the index.
- [ ] Every prior transcript cite matches the certified transcript, including page and line, and accounts for any errata.
- [ ] No pair relies on a row flagged `privileged` in the record index.
- [ ] Each INTRODUCE step has a drafted denial branch.
- [ ] The jurisdiction's foundation requirement has been checked against the federal sequence above.
- [ ] Exhibit numbers assigned and copies prepared for the witness, the reporter, and each appearing party.
