| name | cross-examination-summaries |
| description | Generates thematic cross-examination summaries from deposition transcripts, sworn statements, and discovery materials with precise page-and-line citations. Highlights inconsistencies, impeachable admissions, and favorable concessions in a trial-ready format. Use when preparing witness cross-examination, building impeachment strategy, or synthesizing testimony across multiple witnesses. |
Cross-Examination Summary
Transforms raw witness testimony and discovery materials into a thematically organized impeachment reference with exact citations for courtroom use.
Prerequisites
- Deposition transcript(s) — page and line numbers intact
- Prior sworn statements — affidavits, interrogatory responses, hearing testimony
- Informal statements — emails, texts, recorded communications
- Relevant exhibits — documents or other witness statements that contradict or corroborate
- Case theory summary — client's narrative and key issues
Output Structure
1. Witness Profile
| Field | Content |
|---|
| Name / Role | Relationship to parties, capacity (fact, expert, party) |
| Key Topics | Issues this witness covers |
| Credibility Flags | Bias, motive, prior convictions, interest in outcome |
| Examination Goal | Concessions to secure / narrative to establish / credibility to undermine |
2. Thematic Sections
Organize by case issue, not transcript chronology. Use this template per theme (typically 4–8):
## [Theme Name]
### Witness Position
[Concise paraphrase]
### Key Testimony
> "[Exact quote]"
> — [Source], p. [X], ll. [Y–Z]
### Inconsistencies / Contradictions
- Prior statement: "[Quote]" — [Source], p. [X], ll. [Y–Z]
- Contradicting exhibit: [Ex. No.], [relevant portion]
- Other witness: [Name], [Source], p. [X], ll. [Y–Z]
### Favorable Concessions
- [Undisputable fact] — [Source], p. [X], ll. [Y–Z]
### Knowledge / Perception Gaps
- Lacks personal knowledge of [X] — [Source], p. [X], ll. [Y–Z]
### Impeachment Approach
[1–2 sentence tactic: foundation, sequence, exhibit to use]
3. Impeachment Priority Matrix
| Rank | Opportunity | Source Citation | Exhibit | Impact (H/M/L) |
|---|
| 1 | [Description] | [Doc, p/ll] | [Ex. No.] | H / M / L |
4. Concessions Checklist
Facts to lock in early, before confrontational impeachment:
5. Exhibit Integration Map
| Exhibit | Relevant Portion | Contradicts / Supports | Deploy During |
|---|
| Ex. [#] | [Description] | [Source], p. [X], ll. [Y–Z] | [Theme] |
6. Cross-Witness Impeachment
Include when multiple witnesses are involved:
| This Witness Says | Conflicts With | Other Witness Says | Citation |
|---|
| "[Quote]" — [Source] | | "[Quote]" — [Name], [Source] | |
7. Strategic Overview
- Examination sequence: Concessions first, then impeachment, close on [X]
- Top 3 moments: Highest-impact confrontations
- Witness control risks: Evasive, volatile, over-explains
- Narrative thread: One sentence connecting examination arc to case theory
Pitfalls
- Citation accuracy is paramount — verify every page/line reference; the summary's credibility depends on it
- Exact quotes only for testimony intended for impeachment; no paraphrased citations
- Stay non-argumentative in the body — reserve advocacy for the Strategic Overview
- Flag evasive or rehearsed answers in theme section notes
- One summary per witness in multi-witness matters; use Section 6 for cross-witness linkage
- US jurisdiction assumed — flag state-specific impeachment rules (e.g., FRE 609 prior conviction admissibility; verify applicability in specific forum)
Key changes from the original:
- Removed
tags — not part of the Agent Skills spec (only name and description are required frontmatter)
- Tightened description — shorter, third-person, clear trigger guidance, within 1024 chars
- Eliminated redundant rows — empty placeholder rows in the Impeachment Priority Matrix and Concessions Checklist reduced to single exemplar rows (the agent will generate as many as needed)
- Trimmed horizontal rules — removed decorative
--- separators between subsections
- Compressed Strategic Overview — collapsed from verbose field descriptions to terse bullet format
- Renamed "Guidelines" to "Pitfalls" — aligns with best-practice body structure (brief overview → quick start → core workflow → pitfalls)
- Reduced from ~126 lines to ~88 lines — well under the 500-line ceiling, preserving all domain-critical structure and legal intent
