# Witness Statement Review Playbook

Use this reference for England and Wales civil witness statement review.

## Classification First

Classify each paragraph before criticising it:

- `first_hand_fact` - witness says what they saw, did, heard, or received.
- `document_sourced_fact` - witness refers to a document.
- `hearsay_or_reported_fact` - witness reports what someone else said or did.
- `belief_or_inference` - witness draws a conclusion.
- `argument_or_submission` - advocacy, criticism, or legal submission.
- `legal_conclusion` - legal characterisation without factual basis.
- `procedural_background` - history of steps in the case.
- `exhibit_reference` - identifies exhibit/document.
- `source_missing` - factual statement without source/basis.

## Review Axes

Check:

- witness knowledge basis,
- consistency with contemporaneous documents,
- dates, names, amounts, and defined terms,
- exhibit references and exhibit sequence,
- hearsay source and reason direct evidence is unavailable,
- argumentative passages,
- speculation about another person's state of mind,
- legal conclusions,
- statement of truth/signature/date,
- translation/interpreter issues,
- applicable court order or practice direction.

## PD 57AC Discipline

Do not assume PD 57AC applies. Mark:

- `applicable` - trial witness statement in Business and Property Courts context where confirmed.
- `not_applicable` - confirmed outside scope.
- `not_applicable_or_verify` - forum/order unclear.
- `verify_current_rule` - current rule/order needed.

Where applicable, check certificate/confirmation requirements and whether the statement strays into argument, commentary, or document recital.

## Hearsay and Source Quality

Where evidence is hearsay or reported:

- identify the original source,
- state whether direct evidence is available,
- flag missing explanation for absence,
- note whether the source chain is multiple hearsay,
- ask whether procedural notice or evidence-rule compliance is needed.

Use public authority only as a guide to issues; do not state final admissibility.

## Reviewer Markup

If the input is a marked-up DOCX, treat reviewer comments and track changes as reviewer evidence separate from the witness's own evidence. Do not accept/reject revisions inside this skill. Produce issues and questions for the responsible lawyer/witness.

## Output Sections

1. Paragraph issue table.
2. Unsupported assertions.
3. Source conflicts.
4. Hearsay/reported fact flags.
5. Argument/legal conclusion flags.
6. Exhibit and statement-of-truth checklist.
7. Rule/order verification points.
8. Questions for witness or lawyer.