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:

1. Deponent identity — name, role, party/non-party status
2. Topics — subject matter; 30(b)(6) notice topics if applicable
3. Case materials — produced documents, pleadings, prior testimony
4. 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 building
• deposition-questioning-techniques — document use during examination
• deposition-30b6-corporate-rep — corporate representative specifics

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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