skills/witness-statement-drafter/SKILL.md

---
name: witness-statement-drafter
description: >-
  Draft first-person witness statements, affidavits, declarations, or proofs of
  evidence from a witness's own account. Use when factual evidence must identify
  personal knowledge, information sources, documents, exhibits, uncertainty,
  language, preparation method, and current forum formalities.
---

# Witness Statement Drafter

Preserve the witness's evidence, vocabulary, uncertainty, and independence. A
statement is not written submissions in the witness's voice.

## Intake and interview

Obtain the forum rules and order, issues, pleadings, prior accounts, interview
notes or recording, relevant documents, chronology, witness role and capacity,
language and literacy, memory aids, source of information, exhibits, disclosure
status, privilege boundaries, vulnerabilities, deadline, and statement of truth
or oath requirements.

## Drafting method

1. Explain purpose, disclosure and cross-examination consequences, truth duty,
   privilege limits, document preservation, and the witness's right to correct the draft.
2. Establish identity, role, relationship to the parties, relevant experience,
   and how the statement was prepared.
3. Organise evidence chronologically or by issue in numbered first-person paragraphs.
4. State only facts the witness could properly give orally. Identify personal
   observation, refreshed recollection, usual practice, inference, and information
   or belief with its source.
5. Use the witness's own words and level of certainty. Preserve “I do not know,”
   “I do not recall,” estimates, reconstructed dates, and qualified recollection.
6. Link documents and exhibits with accurate identifiers. Do not imply the
   witness created, sent, received, read, or understood a document without a basis.
7. Reconcile material differences from prior statements, pleadings, documents,
   and other accounts; record the witness's explanation rather than conceal it.
8. Exclude legal argument, commentary on others' motives, inadmissible hearsay,
   expert opinion, privileged content, and unnecessary personal data unless proper.
9. Record interpreter, translation, accessibility, interview, drafting,
   document-review, and remote-signing circumstances where required.
10. Have the witness review the full statement and exhibits, make genuine
    corrections, and sign or swear only the approved final version.

## Output

Provide the draft statement, exhibit list, knowledge-and-source schedule,
uncertainty and inconsistency note, formalities checklist, and unresolved questions.

## Guardrails

Never invent recollection, improve certainty, harmonise accounts artificially,
coach a false answer, suppress adverse facts, or sign for the witness. Do not use
collective corporate knowledge as personal knowledge. Verify current format,
statement-of-truth, oath, filing, service, and language requirements.