| name | witness-prep-session |
| title | Deposition Witness Preparation |
| description | Runs ethics-compliant deposition witness-prep workflows for US civil litigation. Use when preparing party, fact, expert, or 30(b)(6) witnesses for deposition, including mock cross-examination, exhibit review, vulnerability mapping, day-of logistics, and post-deposition debrief. Covers intake through deposition day under FRCP 30. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/witness-prep-session |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
Deposition Witness Preparation
Ethics-compliant witness-prep workflow from intake through deposition day. Scope is limited to memory-refresh and communication coaching — never script answers or feed facts.
Quick Start
Gather before first session:
- Deposition notice/subpoena with date, time, site
- Witness identity, role, type (party / fact / expert / 30(b)(6))
- Notice scope: topics, exhibit requests, known objections or court orders
- Prior statements, productions, disclosures, privilege boundaries
- Case theories, weaknesses, and key adverse topics
- Venue rules (FRCP 30 or state analogue)
Intake Packet
Case:
Venue:
Depo date:
Witness name / role / type:
Risk topics:
Known documents:
Known contradictions:
Prior testimony sources:
Privilege-sensitive areas:
30(b)(6) topics (if applicable):
Session length constraints:
Session Model
| Profile | Sessions | Structure |
|---|
| Straightforward fact witness | 1 | 4–6 h consolidated |
| Standard matter (default) | 2 | 2×(2–4 h), 1–7 day gap |
| Complex or anxious witness | 3 | 2–3 h each, targeted coaching |
| 30(b)(6) corporate rep | 2–3 | Topic-by-topic for each noticed topic |
| High-volume documents | 2–3 | Add dedicated exhibit walkthrough |
Core Workflow
1. Orientation and Document Review (Session 1)
- Set expectations: truth-only, no guessing, admit uncertainty
- Explain deposition mechanics: oath, transcript, objections, court reporter
- Establish behavioral rules: wait for full question, clarify if unclear, answer only what is asked, pause before answering, say "I don't know / recall" when true
- Walk all core documents; record familiarity in a tracking table:
Doc | Role (Author/Recipient/Ref) | Significance | Witness Understanding | Risks
- Map each topic: why it matters, what witness recalls, high-risk subtopics
- Assign homework: review flagged docs, note concerns
2. Mock Examination (Session 2)
- Recheck anxiety, document review completion, new recollections
- Run mock exam with real exhibits and escalating pressure: warm-up, topic exploration, document confrontation, detail probing, commitment questions, impeachment setups
