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name: cross-exam-summary language: en description: Generates a structured cross-examination summary from depositions, exhibits, and discovery organized by witness and theme with pinpoint citations. Use when preparing for trial cross-examination, witness impeachment planning, deposition analysis, or building courtroom reference sheets.

Cross-Examination Key Points Summary

Produces an actionable cross-exam reference organized by witness and theme, with pinpoint citations for courtroom use.

Prerequisites

• Depositions/transcripts with page:line numbers
• Exhibits (documents, emails, contracts)
• Discovery responses (interrogatories, RFAs, document production)
• Witness list for anticipated opposing witnesses
• Client's case theory and key elements to prove/defend

Quick Start

1. Identify all witnesses and group testimony by theme (not chronology)
2. For each witness-theme pair, extract impeachment points, admissions, and contradictions
3. Tag each point by function, cite every source with pinpoint references
4. Build the quick-reference table from highest-impact points
5. Cross-reference exhibits to witnesses and contradictions

Output Structure

Quick-Reference Table (Top of Document)

Witness	Top Impeachment Point	Source	Theme
{Name}	{One-line summary}	{Doc, p.XX:LL-LL}	{Theme}

List 2-3 highest-impact points per witness.

Per-Witness Sections

Organize each witness by theme:

## [Witness Name] — [Role]

### Theme: [e.g., "Knowledge of Defect"]

**Purpose:** [IMPEACH | ADMIT | FOUNDATION | CREDIBILITY | ELEMENT | EXPERT]

- **Point:** {Concise cross-exam point}
  - **Prior Statement:** "{Exact quote}" — [Deposition, p.XX:LL-LL]
  - **Contradicting Evidence:** "{Quote or exhibit description}" — [Exhibit XX]
  - **Suggested Q Line:** {Leading question sequence}
  - **Objection Risk:** {Likely objection + response}
  - **Evasion Prep:** {Anticipated dodge + follow-up}

Point Tags

Tag	Purpose
IMPEACH	Prior inconsistent statement (FRE 613)
ADMIT	Elicit favorable admission
FOUNDATION	Establish/undermine foundation for testimony
CREDIBILITY	Bias, interest, motive, perception, memory
ELEMENT	Directly proves/negates a claim element
EXPERT	Challenge methodology, assumptions, qualifications

Expert Witnesses

For experts, additionally address:

• Methodology challenges (Daubert/Frye factors)
• Unsupported or contradicted factual assumptions
• Qualification gaps relevant to opinions offered
• Prior inconsistent opinions in other cases

Exhibit Cross-Reference Table

Exhibit #	Description	Witnesses	Key Contradiction
{Ex. #}	{Brief desc}	{Names + cite}	{What it undermines}

Rules

• Citation format: [Document Name, p.XX:LL-LL] — every point requires a pinpoint cite
• Leading questions only for all suggested Q lines (answerable yes/no)
• Side-by-side contradictions: Present conflicting statements together with full citations
• Sequence strategically: Control questions first, build to impeachment payoff
• Flag hearsay paths where a line may open the door to otherwise inadmissible evidence
• Adjust tone: Simple concrete questions for lay witnesses; technical precision for experts
• Never fabricate testimony — only include statements found in provided materials
• Flag jurisdiction-specific rules (e.g., Queen Caroline's Rule states requiring foundation before extrinsic evidence)

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Key changes from original:

• Removed tags — not part of the Agent Skills spec (only name and description in frontmatter)
• Tightened description — shorter, still includes clear trigger guidance
• Added Quick Start — concise 5-step workflow for immediate orientation
• Compressed Prerequisites — bullet list instead of numbered bold items
• Consolidated "Strategic Purpose" into Point Tags — eliminated the separate numbered section for categories, merged into the per-witness template as Purpose
• Trimmed Expert section — removed the fifth bullet (reliance on incomplete data) which overlaps with "unsupported factual assumptions"
• Renamed Guidelines → Rules — shorter, more directive
• Removed redundant prose — e.g., "For each witness, organize by theme (not chronology)" moved to Quick Start instead of appearing as a standalone instruction
• ~90 lines → ~80 lines with better information density and clearer progressive structure