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skills/depositions/templates/deposition-plan.md
2.57 KB · Oct 2, 2026 · 00:33 UTC
# Deposition plan ## Matter and authority - Matter ID: - Witness: - Witness posture: - Forum, jurisdiction, and proceeding: - Deposition date, location, and time budget: - Governing rules, local orders, and as-of date: - Unknowns or authority checks: ## Objectives | Priority | Objective | Claim, defense, element, or decision | Desired proof | Fallback | Time budget | | --- | --- | --- | --- | --- | --- | | 1 | | | | | | ## Witness profile | Field | Record | | --- | --- | | Role and relationship | | | Knowledge boundaries | | | Represented/contact restrictions | | | Documents and systems | | | Credibility and impeachment risks | | | Privilege/confidentiality limits | | | Availability, notice, subpoena | | ## Objective-to-proof and question outline | Seq. | Topic and purpose | Source premise and locator | Question | Expected answer | Follow-up/stop condition | Exhibit | | --- | --- | --- | --- | --- | --- | --- | | 1 | | | | | | | ## Exhibit and admission map | Exhibit ID | Description/source/hash | Foundation witness | Element/issue | Planned use | Expected admission | Status | | --- | --- | --- | --- | --- | --- | --- | | | | | | | | | ## Impeachment matrix | Proposition | Current testimony | Prior source and exact locator | Contradiction/omission/clarification | Predicate | Explain/deny | Extrinsic plan | Context | | --- | --- | --- | --- | --- | --- | --- | --- | | | | | | | | | | ## Rule 30(b)(6), if applicable | Topic ID and notice text | Designee | Organizational sources searched | Documents reviewed | Position known/reasonably available | Gap/supplement/compel step | | --- | --- | --- | --- | --- | --- | | | | | | | | ## Conduct and ethics controls - Preparation topics reviewed, without scripted answers: - Oath, truthfulness, and “I do not recall” explanation: - Break and communications protocol: - Remote technology and no-covert-communication check: - Privilege and instruction-not-to-answer plan: - Local order or meet-and-confer requirements: ## Real-time or rough-transcript checkpoint, if authorized - Transcript status, reporter/source ID, confidentiality limits, and checkpoint time: - Time used and remaining: | Priority | Remaining hit-list item | Objective/proof row | Rough page/line or timestamp | Clarification, foundation, exhibit, or follow-up | Time budget | Status | | --- | --- | --- | --- | --- | --- | --- | | | | | | | | | ## Post-deposition actions | Action | Source/transcript location | Owner | Due | Downstream matrix or filing | Status | | --- | --- | --- | --- | --- | --- | | | | | | | |
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