# Quality Control Checklist

Run through this checklist before finalizing any deposition preparation package. Each item should be confirmed; if not met, either fix or flag as an open item.

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## Strategic Alignment

- [ ] Objectives ranked and tied to specific claims, defenses, and issues
- [ ] Issue mapping table completed with all five columns populated
- [ ] Every substantive module has a clear objective connected to the issue map
- [ ] Case posture (next milestone) reflected in the outline's emphasis
- [ ] Posture (taking vs. defending) correctly reflected throughout

## Time and Structure

- [ ] Time allocation table present
- [ ] Total allocated time matches the controlling limit (federal default: 7 hours)
- [ ] Priority rankings reflect the objectives—highest-priority topics get the most time
- [ ] Fallback plan exists if time runs short (which topics to drop or compress)

## Examination Quality

- [ ] Funnel technique present in each substantive module (open → investigative → document → exhaust → lock)
- [ ] FWD boxing-in ("is that all?") included at the end of each substantive module
- [ ] No compound questions in the commit/lock sequences
- [ ] Leading questions reserved for the locking phase, not used prematurely
- [ ] Questions are single-fact (not asking two things at once)

## Exhibits and Impeachment

- [ ] Exhibit integration guide present with foundation scripts for major exhibits
- [ ] Exhibits sequenced so admissions build on one another
- [ ] Impeachment materials table present (even with placeholders where citations are incomplete)
- [ ] Commit-Credit-Confront method applied for each impeachment sequence
- [ ] FRE 612 production risks flagged for any documents used to refresh
- [ ] FRE 613 requirements noted for prior inconsistent statements
- [ ] Authentication scripts adequate under FRE 901
- [ ] Business records foundation (FRE 803(6)) prepared where applicable

## Defending Materials (if defending)

- [ ] Anticipated topics and exhibits section present
- [ ] Vulnerabilities and safe themes identified
- [ ] Ethics-safe prep session agenda included
- [ ] Behavioral guidance for the witness included
- [ ] Objection and privilege framework tied to FRCP 30(c)(2)
- [ ] Rehabilitation topics planned
- [ ] No coaching of false testimony in the prep agenda

## Factual Integrity

- [ ] Every assertion about "what happened" is traceable to a document, pleading, discovery response, or attorney-provided fact
- [ ] Assumed facts are marked with `[ASSUMED]` and not embedded as truths in questions
- [ ] No invented evidence—placeholders used where the record is unknown
- [ ] "Expected answers" labeled as hypotheses, never as facts

## Authority Integrity

- [ ] FRCP and FRE cited using Cornell LII URLs where applicable
- [ ] No invented case citations
- [ ] Any non-rule authorities either have a verifiable URL or are marked `[VERIFY — attorney must confirm]`
- [ ] Citation verification note included: "All non-rule authorities require attorney verification"

## Front Matter and Usability

- [ ] Assumptions Used section present at the top of the output
- [ ] Open Items / Needed Inputs section present
- [ ] At-the-Table One-Pager produced (Lane 2)
- [ ] One-pager includes: top objectives, three must-get admissions, exhibit order, time-topic clock
- [ ] Package is usable under time pressure—can the attorney find the next move quickly?

## Final Prompts for Attorney Decision

Flag these decisions for the attorney:
- [ ] Whether to seek additional time
- [ ] Whether to stipulate to exhibit handling
- [ ] Whether to pursue a protective order
- [ ] Whether to reserve certain topics for another witness
- [ ] Whether to bring a motion under FRCP 30(d)(3) if conduct becomes obstructive