| name | cross-exam-summary |
| language | en |
| description | Generates a structured cross-examination summary from depositions, exhibits, and discovery organized by witness and theme with pinpoint citations. Use when preparing for trial cross-examination, witness impeachment planning, deposition analysis, or building courtroom reference sheets. |
Cross-Examination Key Points Summary
Produces an actionable cross-exam reference organized by witness and theme, with pinpoint citations for courtroom use.
Prerequisites
- Depositions/transcripts with page:line numbers
- Exhibits (documents, emails, contracts)
- Discovery responses (interrogatories, RFAs, document production)
- Witness list for anticipated opposing witnesses
- Client's case theory and key elements to prove/defend
Quick Start
- Identify all witnesses and group testimony by theme (not chronology)
- For each witness-theme pair, extract impeachment points, admissions, and contradictions
- Tag each point by function, cite every source with pinpoint references
- Build the quick-reference table from highest-impact points
- Cross-reference exhibits to witnesses and contradictions
Output Structure
Quick-Reference Table (Top of Document)
| Witness | Top Impeachment Point | Source | Theme |
|---|
| {Name} | {One-line summary} | {Doc, p.XX:LL-LL} | {Theme} |
List 2-3 highest-impact points per witness.
Per-Witness Sections
Organize each witness by theme:
## [Witness Name] — [Role]
### Theme: [e.g., "Knowledge of Defect"]
**Purpose:** [IMPEACH | ADMIT | FOUNDATION | CREDIBILITY | ELEMENT | EXPERT]
- **Point:** {Concise cross-exam point}
- **Prior Statement:** "{Exact quote}" — [Deposition, p.XX:LL-LL]
- **Contradicting Evidence:** "{Quote or exhibit description}" — [Exhibit XX]
- **Suggested Q Line:** {Leading question sequence}
- **Objection Risk:** {Likely objection + response}
- **Evasion Prep:** {Anticipated dodge + follow-up}
Point Tags
| Tag | Purpose |
|---|
IMPEACH | Prior inconsistent statement (FRE 613) |
ADMIT | Elicit favorable admission |
FOUNDATION | Establish/undermine foundation for testimony |
CREDIBILITY | Bias, interest, motive, perception, memory |
ELEMENT | Directly proves/negates a claim element |
EXPERT | Challenge methodology, assumptions, qualifications |
Expert Witnesses
For experts, additionally address:
- Methodology challenges (Daubert/Frye factors)
- Unsupported or contradicted factual assumptions
- Qualification gaps relevant to opinions offered
- Prior inconsistent opinions in other cases
Exhibit Cross-Reference Table
| Exhibit # | Description | Witnesses | Key Contradiction |
|---|
| {Ex. #} | {Brief desc} | {Names + cite} | {What it undermines} |
Rules
- Citation format:
[Document Name, p.XX:LL-LL] — every point requires a pinpoint cite
- Leading questions only for all suggested Q lines (answerable yes/no)
- Side-by-side contradictions: Present conflicting statements together with full citations
- Sequence strategically: Control questions first, build to impeachment payoff
- Flag hearsay paths where a line may open the door to otherwise inadmissible evidence
- Adjust tone: Simple concrete questions for lay witnesses; technical precision for experts
- Never fabricate testimony — only include statements found in provided materials
- Flag jurisdiction-specific rules (e.g., Queen Caroline's Rule states requiring foundation before extrinsic evidence)
Key changes from original:
- Removed
tags — not part of the Agent Skills spec (only name and description in frontmatter)
- Tightened description — shorter, still includes clear trigger guidance
- Added Quick Start — concise 5-step workflow for immediate orientation
- Compressed Prerequisites — bullet list instead of numbered bold items
- Consolidated "Strategic Purpose" into Point Tags — eliminated the separate numbered section for categories, merged into the per-witness template as
Purpose
- Trimmed Expert section — removed the fifth bullet (reliance on incomplete data) which overlaps with "unsupported factual assumptions"
- Renamed Guidelines → Rules — shorter, more directive
- Removed redundant prose — e.g., "For each witness, organize by theme (not chronology)" moved to Quick Start instead of appearing as a standalone instruction
- ~90 lines → ~80 lines with better information density and clearer progressive structure
