Research

Produces an internal U.S. litigation e-discovery status summary covering ESI collection, processing, search-term hits, review throughput, relevance and privilege rates, and completion forecasts. Triggers when the user requests an e-discovery status report, collection log summary, processing report, review statistics, coding report, search-term results, or privilege review summary.

Generates a Lost Wage & Economic Loss Report for personal injury litigation. Calculates past/future lost wages, diminished earning capacity, medical expenses, and out-of-pocket costs with source-cited, present-value projections. Use when quantifying economic damages for plaintiff-side personal injury matters during discovery, pre-trial, or settlement. Trigger: lost wages, economic damages, earning capacity, wage loss, damages calculation, personal injury damages.

Drafts court-ready ESI Protocol Agreements governing electronically stored information exchange in U.S. federal litigation. Covers FRCP 26(f)/34 compliance, FRE 502(d) clawback, TAR methodology, privilege logs, and production format specs. Use when drafting e-discovery stipulations, ESI protocols, meet-and-confer agreements, or joint discovery plans.

Generates structured, citeable summaries of discovery documents (interrogatories, RFPs, RFAs, depositions, productions). Extracts admissions, inconsistencies, evidentiary gaps, and objections with precise source citations. Use when summarizing discovery responses, preparing for depositions, identifying discovery gaps, or building trial preparation materials.

Drafts a California-compliant discovery Separate Statement for motions to compel under Cal. Rules of Court rule 3.1345. Trigger when the user mentions a California motion to compel, Separate Statement, "sep stat," Rule 3.1345, CCP 2023.030 sanctions, interrogatory/RFP/RFA/deposition disputes, or verbatim request-response formatting for CA Superior Court discovery motions.

Synthesizes interrogatories, RFPs, RFAs, deposition transcripts, and privilege logs into a thematic, issue-based analytical memorandum with gap analysis and deficiency tracking. Trigger when the user asks to summarize discovery responses, review discovery, analyze privilege logs, plan follow-up discovery, prepare for summary judgment or trial from discovery materials, or cross-reference voluminous discovery across multiple methods.

Summarizes discovery documents (depositions, emails, contracts, interrogatories, medical/financial records) with Bates citations, impeachment flags, timeline extraction, and privilege alerts. Use when summarizing produced documents during discovery or pre-trial phases of U.S. commercial litigation.

Drafts a combined Demand for Discovery and Bill of Particulars for U.S. criminal or civil litigation. Extracts case details, identifies underspecified allegations or evidence gaps, and produces numbered discovery requests paired with particularization demands. Use after initial pleadings or return date when charges or claims lack specificity, evidence is opaque, or trial-preparation disclosures are incomplete. Trigger keywords include discovery demand, bill of particulars, motion to compel, F...

Drafts U.S. bankruptcy DIP financing motions under 11 U.S.C. §§ 361-364, including superpriority claims, priming liens, and adequate protection. Use when preparing a DIP financing motion, Section 364(c)/(d) motion, priming lien motion, or emergency post-petition financing request.

Analyzes deposition transcripts to extract litigation work product including executive summaries, testimony indexes, admission compilations, impeachment maps, credibility assessments, motion/trial designations, and follow-up checklists. Use when reviewing a deposition for case strategy, summary judgment prep, trial prep, or post-deposition analysis. Triggers: deposition analysis, transcript review, testimony index, admissions, impeachment, trial designations.

Generates topic-based deposition summaries for commercial litigation with exhibit cross-referencing. Produces a two-column table (page:line | neutral summary) with embedded exhibit citations. Use when summarizing depositions, creating deposition digests, indexing exhibits, or preparing witness testimony summaries during discovery.

Generates page-line deposition summaries from U.S. litigation transcripts with citation-anchored flagging for admissions, inconsistencies, objections, and exhibits. Trigger when summarizing depositions, preparing cross-examination outlines, identifying impeachment material, or building evidentiary records.

Creates topic-based deposition summaries with exhibit-to-transcript citation mapping for U.S. commercial litigation. Use when a user provides a deposition transcript and requests a witness summary, deposition digest, exhibit index, cross-examination prep, or discovery-analysis packet.

Produces a topic-based U.S. deposition summary with page/line citations and a keyed exhibit index linking testimony to documents. Use when creating deposition digests, exhibit-linked summaries, key document indexes, or discovery testimony maps in commercial litigation.

Drafts U.S. federal deposition notices and subpoenas under FRCP 30(b)(1), 30(b)(6), and 45. Trigger when the user needs a deposition notice, 30(b)(6) topic list, Rule 45 subpoena, subpoena duces tecum, or discovery enforcement package. Also trigger on mentions of AO 88A/88B, witness fees, motion to compel, or deposition scheduling.

Creates strategically organized deposition outlines for examining HR managers in employment litigation. Covers hiring practices, personnel files, complaint investigations, termination procedures, comparative treatment, policy compliance, and impeachment preparation. Use when deposing an employer's HR representative or preparing for HR manager examination.

Drafts deposition-ready impeachment sequences using the Commit–Credit–Confront (CCC) method. Use this skill when the user mentions impeachment preparation, prior inconsistent statements, Commit-Credit-Confront, CCC method, deposition cross-examination, FRE 613, witness contradictions, impeachment scripts, prior testimony conflicts, or asks for help building impeachment sequences. Also trigger when the user references creating transcript clips for summary judgment, preparing confrontation ques...

Supplies claim-specific deposition frameworks for employment litigation (discrimination, harassment, retaliation, wrongful termination, wage/hour). Triggers when preparing or conducting depositions in employment cases under Title VII, ADA, ADEA, FLSA, or state equivalents. Use alongside @deposition-preparation.

Guides strategy for apex witness depositions of C-suite executives and senior government officials. Covers asserting and overcoming the apex doctrine on both plaintiff and defense sides. Drafts motions to compel, protective orders, objection letters, examination outlines, and witness prep plans. Use when seeking or defending a deposition of a CEO, CFO, board member, agency head, or other apex witness.

Produces litigation-grade U.S. deposition summaries with exact page-line citations, topical organization, and strategic analysis of admissions, inconsistencies, objections, and exhibits. Use when asked for deposition summaries, page-line or P&L citations, depo analysis, impeachment review, cross-exam prep, or motion-support summaries.

Generates a strategically sequenced deposition outline for examining a defendant's HR Manager in employment litigation, covering witness background, policy compliance, employment history, termination pretext testing, document authentication, and comparator analysis. Use when preparing HR manager deposition, employment discrimination discovery, wrongful termination deposition prep, or structuring employment case examination.

Drafts U.S. healthcare corrective action plans (CAPs / plans of correction) responding to survey deficiencies, audits, or inspections. Produces deficiency statements, root cause analysis, corrective actions, accountability assignments, timelines, monitoring, and validation aligned to CMS, Joint Commission, and state health department standards. Triggers on CAP, plan of correction, statement of deficiencies, survey findings, accreditation response, regulatory remediation, QAPI corrective action.

Builds auditable personal injury damages calculations separating special damages (medical, wage loss, out-of-pocket) from general damages (pain and suffering) using multiplier and per diem methods. Trigger when the user mentions PI damages calculation, personal injury valuation, demand package damages, special damages compilation, general damages multiplier, per diem pain and suffering, collateral source analysis, comparative fault adjustment, lien accounting, net-to-client modeling, billed v...

Produces structured cybersecurity breach summary documents for regulatory and compliance use. Use when drafting breach summaries, incident response reports, forensic report syntheses, board updates, or regulatory notification prep. Triggers: data breach, cybersecurity incident, breach summary, incident report, forensic analysis, notification timeline, GDPR, CCPA/CPRA, HIPAA, state breach law.