Deposition Outline: HR Manager (Employment Litigation)

Produces a topic-bullet deposition outline (not verbatim script) targeting institutional knowledge, policy compliance gaps, decision-making pretext, and comparator evidence.

Prerequisites

If any item is missing, pause and ask before generating.

Pleadings — complaint, answer, amended pleadings with causes of action identified (discrimination, retaliation, wrongful termination, FMLA/ADA, breach of contract)
Chronology — hire date through adverse action; key dates for protected activity, performance docs, complaints, termination
Deponent ID — full name, title, tenure; corporate disclosures, org charts, prior testimony
Personnel file — application, offer letter, job descriptions, evaluations, disciplinary records, termination letter
Discovery production — emails, investigation files, policies/handbooks, training records
Comparator data — similarly situated employees identified from discovery

Output Structure

Generate sections in order. Use topic headings with bullet-point question areas. Reference exhibits by placeholder.

1. Preliminary Matters

| Item | Content | |------|---------| | Admonitions | Oath, audible answers, clarify-don't-guess, no breaks during pending questions, duty to correct | | Stipulations | Transcript use, signature reservation, objection protocol | | Confidentiality | Protective order scope for personnel/medical/proprietary data |

2. Witness Background & Authority

[ ] Career progression — dates, titles, reporting chain per role
[ ] Education, HR certifications (PHR/SPHR/SHRM), specialized training
[ ] Training on: anti-discrimination law, ADA interactive process, FMLA admin, investigations, termination procedures
[ ] Scope: advisory vs. decision-making; role in hiring, discipline, investigations, terminations
[ ] Involvement with plaintiff — when, capacity, at whose direction
[ ] Reporting relationship to legal counsel; when counsel consulted

3. Policies & Compliance Infrastructure

For each relevant policy (EEO, anti-harassment, complaint/investigation, progressive discipline, PIP, attendance, FMLA/ADA leave, accommodation):

[ ] Adoption date, drafter/approver, legal review status
[ ] Communication method (handbook, intranet, orientation, training)
[ ] Employee acknowledgment process; last revision date
[ ] Witness's own-words explanation of the policy

Practice vs. paper:

[ ] Deviations from written policy
[ ] Who authorizes exceptions; documentation method
[ ] Enforcement consistency across employees

Training:

[ ] Frequency, format, mandatory attendance tracking
[ ] Whether plaintiff's supervisors completed required training before relevant decisions

4. Plaintiff's Employment History

Hiring: Date, position, duties, salary, decision-maker, qualifications cited

Performance (each evaluation period):

[ ] Evaluator, rating system, scores, strengths, deficiencies
[ ] Objective/measurable vs. subjective standards
[ ] Rating changes after protected activity
[ ] Standard consistency across similarly situated employees

Discipline (each event):

[ ] Date, conduct/performance issue, initiator, investigation conducted
[ ] Plaintiff's opportunity to respond
[ ] Policy cited; progressive discipline followed?
[ ] Comparator discipline for same conduct

Complaints & investigations:

[ ] By plaintiff: date, method, recipient, written record, investigation, findings, remedial action, notification
[ ] Against plaintiff: same details — probe whether investigated more aggressively or credited more readily

5. Termination Decision

Primary pretext-testing section.

[ ] Date decision made vs. date communicated
[ ] Final decision-maker identity
[ ] Reasons cited contemporaneously in termination documentation
[ ] Reasons communicated to plaintiff at termination
[ ] Whether litigation position matches contemporaneous reasons
[ ] Alternatives considered (training, transfer, final PIP) — if not, why not
[ ] Every person involved: supervisor, department head, HR, executives
[ ] Each decision-maker's knowledge of: performance, complaints, protected characteristics, protected activity
[ ] Legal counsel: when consulted, advice given, whether followed
[ ] Temporal proximity between protected activity and termination
[ ] Why issues not addressed earlier; why termination-worthy now

6. Documentary Examination

Foundation for each key document:

| Element | Question | |---|---| | Recognition | Recognize this document? | | Creation/receipt | Created, received, or reviewed it? | | Business records | Created in ordinary course, at or near the time? | | Accuracy | Accurately reflects information described? | | Reliance | Relied on in employment decisions? |

Sequencing: Lock testimony before presenting impeaching documents. Use documents to refresh recollection. Identify referenced-but-unproduced documents.

Priority categories:

[ ] Personnel file completeness
[ ] Investigation files (intake, notes, conclusions, remedial actions)
[ ] HR/supervisor/management emails re: plaintiff
[ ] Performance evaluations and disciplinary records
[ ] Termination approval chain documentation

7. Comparator / Disparate Treatment

[ ] All employees in same/similar position during relevant period
[ ] Protected characteristics for each (age, race, sex, disability, protected activity)
[ ] Comparable performance/conduct issues
[ ] Discipline received vs. plaintiff's
[ ] Witness's criteria for "similarly situated"
[ ] Policy waivers/exceptions granted to others — who, justification, documentation

8. Reservation & Follow-Up

[ ] Topics reserved pending document review or other depositions
[ ] Areas to revisit if later testimony contradicts
[ ] Cross-reference against complaint/answer: every material allegation addressed
[ ] Cross-reference against discovery responses: all witness-knowledge topics covered

Guidelines

Topic bullets, not scripts — maintain flexibility for follow-up
Sequence strategically — build the record before impeaching; establish what the witness should have known before testing what they claim
Anticipate objections — prepare alternative phrasings and additional foundation
Flag knowledge gaps — if witness disclaims knowledge, probe whether their role required it
[VERIFY] Jurisdiction — federal and state employment statutes vary; confirm applicable law (Title VII, ADEA, ADA, FMLA, state equivalents) before generating
Ethics — do not coach answers or misrepresent documents; adhere to applicable rules of professional conduct

Key changes from the original:

Added metadata block with author, practice_areas, document_types, skill_modes per spec
Added prerequisite guard ("If any item is missing, pause and ask before generating")
Added [VERIFY] flag on jurisdiction guideline per codebase convention
Tightened prose throughout — removed redundant phrasing ("effectiveness assessment methods", "adapt in real time" which is implicit), compressed label text, collapsed multi-line items where possible
Removed the standalone "adapt in real time" guideline — Claude already understands outlines are flexible
Reduced from 151 to ~130 lines while preserving all legal domain content and strategic sequencing

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