deposition-outline-hr-manager

name	deposition-outline-hr-manager
title	Deposition Outline — HR Manager
description	Creates strategically organized deposition outlines for examining HR managers in employment litigation. Covers hiring practices, personnel files, complaint investigations, termination procedures, comparative treatment, policy compliance, and impeachment preparation. Use when deposing an employer's HR representative or preparing for HR manager examination.
author	CaseMark
author_url	https://github.com/CaseMark/skills/tree/main/skills/legal/deposition-outline-hr-manager
license	Apache-2.0
version	0.1.0
execution_mode	open
jurisdiction	us
practice	employment
language	en

Deposition Outline — HR Manager

Generates a structured deposition outline for examining the defendant employer's HR manager in contested employment matters.

Quick Start

Gather before drafting:

• Operative pleadings — claims, defenses, disputed issues
• Personnel file — applications, evaluations, disciplinary records, termination docs
• HR policies — handbook, anti-discrimination policy, complaint procedures, progressive discipline
• Communications — emails, texts, investigation notes involving the HR manager
• Prior testimony — declarations, interrogatory responses, prior depositions
• Comparator data — similarly situated employees, treatment, outcomes
• Investigation files — complaint reports, investigation summaries

Outline Sections

I. Background and Foundation

• Name, title, reporting structure, tenure
• HR education, certifications (PHR/SPHR)
• Role in hiring, discipline, termination decisions
• Lock in: "You're the person most knowledgeable about HR policies at [Company]?"

II. Policies and Procedures

• Authenticate handbook version in effect
• Anti-discrimination, anti-harassment, complaint, progressive discipline policies
• Termination approval process
• Pin down deviations: "Was this policy followed in [plaintiff]'s case?"

III. Plaintiff's Employment History

• Hiring decision (who, why, qualifications)
• Duties, performance expectations, evaluations, trajectory
• Commendations, raises, promotions, prior discipline
• Establish competence baseline before adverse events

IV. Triggering Events

• When and how HR became involved
• Protected activity timeline (complaint, leave request, whistleblowing)
• HR's response and communications with decision-makers
• Temporal proximity: timeline between protected activity and adverse action

V. Investigation

• Investigator, methodology, timeline, witnesses, documents reviewed
• Findings, conclusions, credibility assessments
• Probe thoroughness: compare investigation of plaintiff vs. others

VI. Termination Decision

• Decider identity — HR as decider or advisor?
• Stated reasons — lock in precisely
• Supporting documents; decision date vs. communication date