deposition-outline-hr-manager

# 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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