skills/depositions/templates/deposition-plan.md

# 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 |
| --- | --- | --- | --- | --- | --- |
|  |  |  |  |  |  |