| name | deposition-document-assembly |
| title | Deposition Document Assembly |
| 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. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/deposition-document-assembly |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
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 |
