depo-outline-hr-manager

# Deposition Outline: HR Manager (Employment Litigation)

Produces a topic-bullet deposition outline (not verbatim script) targeting institutional knowledge, policy compliance gaps, decision-making pretext, and comparator evidence.

## Prerequisites

If any item is missing, pause and ask before generating.

1. **Pleadings** — complaint, answer, amended pleadings with causes of action identified (discrimination, retaliation, wrongful termination, FMLA/ADA, breach of contract)
2. **Chronology** — hire date through adverse action; key dates for protected activity, performance docs, complaints, termination
3. **Deponent ID** — full name, title, tenure; corporate disclosures, org charts, prior testimony
4. **Personnel file** — application, offer letter, job descriptions, evaluations, disciplinary records, termination letter
5. **Discovery production** — emails, investigation files, policies/handbooks, training records
6. **Comparator data** — similarly situated employees identified from discovery

## Output Structure

Generate sections in order. Use topic headings with bullet-point question areas. Reference exhibits by placeholder.

### 1. Preliminary Matters

| Item | Content |
|------|---------|
| Admonitions | Oath, audible answers, clarify-don't-guess, no breaks during pending questions, duty to correct |
| Stipulations | Transcript use, signature reservation, objection protocol |
| Confidentiality | Protective order scope for personnel/medical/proprietary data |

### 2. Witness Background & Authority

- [ ] Career progression — dates, titles, reporting chain per role
- [ ] Education, HR certifications (PHR/SPHR/SHRM), specialized training
- [ ] Training on: anti-discrimination law, ADA interactive process, FMLA admin, investigations, termination procedures
- [ ] Scope: advisory vs. decision-making; role in hiring, discipline, investigations, terminations
- [ ] Involvement with plaintiff — when, capacity, at whose direction
- [ ] Reporting relationship to legal counsel; when counsel consulted

### 3. Policies & Compliance Infrastructure

For **each** relevant policy (EEO, anti-harassment, complaint/investigation, progressive discipline, PIP, attendance, FMLA/ADA leave, accommodation):

- [ ] Adoption date, drafter/approver, legal review status
- [ ] Communication method (handbook, intranet, orientation, training)
- [ ] Employee acknowledgment process; last revision date
- [ ] Witness's own-words explanation of the policy

**Practice vs. paper:**
- [ ] Deviations from written policy
- [ ] Who authorizes exceptions; documentation method
- [ ] Enforcement consistency across employees

**Training:**
- [ ] Frequency, format, mandatory attendance tracking
- [ ] Whether plaintiff's supervisors completed required training before relevant decisions

### 4. Plaintiff's Employment History

**Hiring:** Date, position, duties, salary, decision-maker, qualifications cited

**Performance (each evaluation period):**
- [ ] Evaluator, rating system, scores, strengths, deficiencies
- [ ] Objective/measurable vs. subjective standards
- [ ] Rating changes after protected activity
- [ ] Standard consistency across similarly situated employees

**Discipline (each event):**
- [ ] Date, conduct/performance issue, initiator, investigation conducted
- [ ] Plaintiff's opportunity to respond
- [ ] Policy cited; progressive discipline followed?
- [ ] Comparator discipline for same conduct

**Complaints & investigations:**
- [ ] **By** plaintiff: date, method, recipient, written record, investigation, findings, remedial action, notification
- [ ] **Against** plaintiff: same details — probe whether investigated more aggressively or credited more readily

### 5. Termination Decision

Primary pretext-testing section.

- [ ] Date decision made vs. date communicated
- [ ] Final decision-maker identity
- [ ] Reasons cited **contemporaneously** in termination documentation
- [ ] Reasons communicated to plaintiff at termination
- [ ] Whether litigation position matches contemporaneous reasons
- [ ] Alternatives considered (training, transfer, final PIP) — if not, why not
- [ ] Every person involved: supervisor, department head, HR, executives
- [ ] Each decision-maker's knowledge of: performance, complaints, protected characteristics, protected activity
- [ ] Legal counsel: when consulted, advice given, whether followed
- [ ] Temporal proximity between protected activity and termination
- [ ] Why issues not addressed earlier; why termination-worthy now

### 6. Documentary Examination

Foundation for each key document:

| Element | Question |
|---|---|
| Recognition | Recognize this document? |
| Creation/receipt | Created, received, or reviewed it? |
| Business records | Created in ordinary course, at or near the time? |
| Accuracy | Accurately reflects information described? |
| Reliance | Relied on in employment decisions? |

**Sequencing:** Lock testimony **before** presenting impeaching documents. Use documents to refresh recollection. Identify referenced-but-unproduced documents.

**Priority categories:**
- [ ] Personnel file completeness
- [ ] Investigation files (intake, notes, conclusions, remedial actions)
- [ ] HR/supervisor/management emails re: plaintiff
- [ ] Performance evaluations and disciplinary records
- [ ] Termination approval chain documentation

### 7. Comparator / Disparate Treatment

- [ ] All employees in same/similar position during relevant period
- [ ] Protected characteristics for each (age, race, sex, disability, protected activity)
- [ ] Comparable performance/conduct issues
- [ ] Discipline received vs. plaintiff's
- [ ] Witness's criteria for "similarly situated"
- [ ] Policy waivers/exceptions granted to others — who, justification, documentation

### 8. Reservation & Follow-Up

- [ ] Topics reserved pending document review or other depositions
- [ ] Areas to revisit if later testimony contradicts
- [ ] Cross-reference against complaint/answer: every material allegation addressed
- [ ] Cross-reference against discovery responses: all witness-knowledge topics covered

## Guidelines

- **Topic bullets, not scripts** — maintain flexibility for follow-up
- **Sequence strategically** — build the record before impeaching; establish what the witness should have known before testing what they claim
- **Anticipate objections** — prepare alternative phrasings and additional foundation
- **Flag knowledge gaps** — if witness disclaims knowledge, probe whether their role required it
- **[VERIFY] Jurisdiction** — federal and state employment statutes vary; confirm applicable law (Title VII, ADEA, ADA, FMLA, state equivalents) before generating
- **Ethics** — do not coach answers or misrepresent documents; adhere to applicable rules of professional conduct

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Key changes from the original:

- **Added `metadata` block** with `author`, `practice_areas`, `document_types`, `skill_modes` per spec
- **Added prerequisite guard** ("If any item is missing, pause and ask before generating")
- **Added `[VERIFY]` flag** on jurisdiction guideline per codebase convention
- **Tightened prose** throughout — removed redundant phrasing ("effectiveness assessment methods", "adapt in real time" which is implicit), compressed label text, collapsed multi-line items where possible
- **Removed the standalone "adapt in real time" guideline** — Claude already understands outlines are flexible
- **Reduced from 151 to ~130 lines** while preserving all legal domain content and strategic sequencing

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