| name | deposition-document-assembly |
| language | en |
| description | Assembles and organizes documents for deposition preparation, producing a document inventory, exhibit list, impeachment index, and gap analysis. Use before building a deposition outline for any deponent type (fact witness, party, corporate rep/30(b)(6), expert) in US federal or state litigation. |
Deposition Document Assembly
Identifies, categorizes, and inventories documents tied to a deponent, then produces an exhibit candidate list, gap analysis, impeachment index, and preparation checklist.
Prerequisites
Collect before starting:
- Deponent identity — name, role, party/non-party status
- Topics — subject matter; 30(b)(6) notice topics if applicable
- Case materials — produced documents, pleadings, prior testimony
- Deponent type — fact witness, party, corporate rep, or expert
Prompt for any missing items before proceeding.
Workflow
1. Identify Documents
Search by three axes:
Connection to deponent: authored, received, CC'd/BCC'd, mentioned by name, custodial (from deponent's files/email).
Topic: key events deponent will testify about, decisions they participated in, relevant communications, applicable policies, business records they maintained.
Prior statements: depositions in this or other cases, affidavits/declarations, interrogatory answers, RFA responses identifying the deponent, written or recorded statements.
2. Build Document Inventory
Create a table with columns: Doc ID, Description, Date, Bates, Connection, Category, Key Pages, Notes.
Connection types: Authored / Received / CC'd / Mentioned / Custodial / Topic-related
Categories: Authentication / Impeachment / Key Fact / Background / Pleading-Discovery
3. Generate Exhibit Candidate List
Create a table with columns: Exhibit #, Document, Bates/ID, Topic, Purpose, Priority (Essential / Likely / Backup).
Choose an organization scheme: chronological (narrative depositions), topical (issue-focused), or strategic (examination sequence).
4. Run Gap Analysis
Check for missing documents by deponent type:
| Deponent Type | Verify Presence Of |
|---|
| Any | Resume/CV, org chart, job description, prior testimony in this case |
| Party | Complaint/Answer, interrogatory responses, RFA responses, produced docs |
| Employee | Personnel file (if relevant), training/disciplinary records, email samples |
| 30(b)(6) rep | Corporate org docs, policies/procedures per notice topic, prior 30(b)(6) testimony |
| Expert | Expert report, CV, publications, fee agreement, prior testimony list, materials considered |
For each gap, document: what is missing, why it matters, potential source, and action required.
5. Build Impeachment Index
For each potential inconsistency, record: document, Bates/ID, exact quote from document, expected testimony, nature of inconsistency, and planned approach.
For each entry include: (1) exact page/paragraph citation, (2) commitment questions before confrontation, (3) follow-up after introduction.
6. Produce Final Package
Output a summary containing:
- Deponent name, role, deposition date
- Document counts by category (authentication, impeachment, key fact, background, pleadings/discovery)
- Gaps identified with required actions
- Preparation checklist:
- Obtain missing documents per gap analysis
- Prepare clean exhibit copies
- Number/tab exhibits; prepare sets for witness, opposing counsel, reporter
- For remote depositions: load documents in presentation software, test screen sharing
- Review impeachment documents; integrate into deposition outline
Pitfalls and Rules
- Impeachment exhibits: Do not pre-disclose if jurisdiction permits surprise; keep separate from main exhibit binder
- 30(b)(6) scope: Exhibits must align with designated notice topics — flag any documents outside scope
- Authentication planning: Note which deponent can authenticate each exhibit for trial (FRE 901-902); plan method per exhibit (witness testimony, self-authentication, stipulation)
- FRCP 30(f): Original exhibits must be annexed to the deposition record unless parties stipulate otherwise — verify local rules
- FRE 408: Label settlement-adjacent communications if used for a non-settlement purpose
Related Skills
deposition-preparation — outline buildingdeposition-questioning-techniques — document use during examinationdeposition-30b6-corporate-rep — corporate representative specifics
Key changes made:
- Removed
tags — not part of the Agent Skills spec
- Tightened description — shorter, third-person, with clear trigger guidance (from 394 to 230 chars)
- Eliminated empty template tables — described column schemas inline instead; Claude knows how to produce tables
- Removed the code-fenced final output template — replaced with a concise bullet list of what to include
- Condensed Phase 1's three sub-tables into compact inline lists — same information, ~60% fewer tokens
- Collapsed "Guidelines" into "Pitfalls and Rules" — tighter section name, same legal substance
- Renamed "Output Structure / Process" to "Workflow" with numbered steps — matches best-practice pattern
- Reduced from 149 lines to ~85 lines — well under the 500-line ceiling
