Deposition Outline — HR Manager

Generates a structured deposition outline for examining the defendant employer's HR manager in contested employment matters.

Quick Start

Gather before drafting:

• Operative pleadings — claims, defenses, disputed issues
• Personnel file — applications, evaluations, disciplinary records, termination docs
• HR policies — handbook, anti-discrimination policy, complaint procedures, progressive discipline
• Communications — emails, texts, investigation notes involving the HR manager
• Prior testimony — declarations, interrogatory responses, prior depositions
• Comparator data — similarly situated employees, treatment, outcomes
• Investigation files — complaint reports, investigation summaries

Outline Sections

I. Background and Foundation

• Name, title, reporting structure, tenure
• HR education, certifications (PHR/SPHR)
• Role in hiring, discipline, termination decisions
• Lock in: "You're the person most knowledgeable about HR policies at [Company]?"

II. Policies and Procedures

• Authenticate handbook version in effect
• Anti-discrimination, anti-harassment, complaint, progressive discipline policies
• Termination approval process
• Pin down deviations: "Was this policy followed in [plaintiff]'s case?"

III. Plaintiff's Employment History

• Hiring decision (who, why, qualifications)
• Duties, performance expectations, evaluations, trajectory
• Commendations, raises, promotions, prior discipline
• Establish competence baseline before adverse events

IV. Triggering Events

• When and how HR became involved
• Protected activity timeline (complaint, leave request, whistleblowing)
• HR's response and communications with decision-makers
• Temporal proximity: timeline between protected activity and adverse action

V. Investigation

• Investigator, methodology, timeline, witnesses, documents reviewed
• Findings, conclusions, credibility assessments
• Probe thoroughness: compare investigation of plaintiff vs. others

VI. Termination Decision

• Decider identity — HR as decider or advisor?
• Stated reasons — lock in precisely
• Supporting documents; decision date vs. communication date
• Alternatives considered (PIP, transfer, demotion)?
• Shifting explanations: compare to interrogatories, position statements, prior testimony

VII. Comparative Treatment

• Similarly situated employees outside protected class
• Same supervisor, position, time period; comparable conduct
• Different outcomes — document systematically:

| Employee | Protected Class | Conduct | Outcome | Decision-Maker | |---|---|---|---|---| | Plaintiff | [class] | [conduct] | Terminated | [name] | | Comparator A | [class] | [comparable] | [outcome] | [name] |

VIII. Pattern and Practice

• Prior discrimination/retaliation complaints in the department
• HR's handling of prior complaints
• EEOC charges or lawsuits involving same decision-makers
• Anti-discrimination training records (when, content, attendance)

IX. Document Authentication

Mark and authenticate: personnel file, investigation files, emails, policy documents, termination approval docs.

X. Impeachment Preparation

• Compare testimony to: interrogatory responses, EEOC position statement, personnel file documents, plaintiff's version
• Note inconsistencies for trial impeachment

Examination Techniques

• Open-ended first: "Tell me everything you know about…" — lock in the narrative
• Then narrow: specific questions with document references
• Commit-credit-confront: get commitment, show favorable document, confront with inconsistency
• Exhaust "I don't recall": use specific documents to refresh recollection

Pitfalls and Checks

• Lock in stated termination reason early — before showing contradictory evidence
• Track which documents were in the file at termination vs. added later
• Note documents missing from file that should be there
• Time allocation: ~60% termination decision and comparators, ~20% policies/investigation, ~20% background/authentication

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Key changes from original:

• Removed tags — not part of the Agent Skills spec (only name, description, license, compatibility, metadata, allowed-tools are valid)
• Restructured to best-practice layout: Quick Start → Core Workflow → Pitfalls and Checks
• Renamed "Prerequisites" → "Quick Start" with tighter formatting
• Renamed "Guidelines" → "Pitfalls and Checks" for clarity
• Removed the "Silence" examination technique — general deposition knowledge Claude already has
• Compressed verbose sections — Investigation, Document Authentication, and Pattern/Practice sections tightened significantly
• Removed redundant overview sentence that repeated the description
• Cut ~30% token count while preserving all domain-specific legal content

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