Extract Key Exhibits From Document Production

---
name: extract-key-exhibits-from-document-production
task_id: trusts-estates-private-client/extract-key-exhibits-from-document-production
description: Closes the gap where agents catalog exhibits in isolation without linking related financial documents to identify undisclosed accounts, quantifying income understatement across all sources, connecting account balance declines to specific transfers, and building a complete asset summary table.
activates_for: [planner, solver, checker]
---

# Skill: Extract Key Exhibits from Document Production — Exhibit Summary Memorandum

## 2. Failure modes the skill is correcting

- Treating the production as a list of isolated exhibits instead of a linked financial record set; each document should be used to corroborate, contradict, or supplement the others
- Not tracing balance changes to the transaction that explains them; a decline between statement dates should be tied to market movement and any specific transfer, withdrawal, or distribution that accounts for the remainder
- Missing undisclosed or under-disclosed accounts signaled by transfers, new counterparties, or account identifiers that do not appear in the financial declaration
- Failing to separate distinct income-suppression mechanisms; compensation, retained earnings, personal expenses run through the business, and similar items must be analyzed separately before aggregation
- Treating retained earnings as a single-purpose item; they can matter both as a valuation input and as a support/income issue, with a double-counting risk if the same economic value is used twice
- Overlooking separation-date conflicts that change asset inclusion, dissipation analysis, and maintenance or support timing
- Omitting a comprehensive asset summary that collects real property, accounts, business interests, vehicles, and other identified assets from the entire production
- Writing conclusions without tying each issue to the source figure, the related document, and the practical discovery consequence

## 3. Legal frameworks / domain conventions that apply

- Financial declaration comparison: treat the declaration as the baseline and test every source document against it for corroboration, contradiction, or supplementation
- Asset tracing and account identification: transfer records, statement headers, and payment logs can reveal institutions, account numbers, counterparties, and hidden balances that warrant targeted discovery
- Income analysis in closely held businesses: below-market owner compensation, retained earnings, diverted business payments, and personal expenses paid by the entity are separate indicators that may support income understatement analysis
- Support and valuation interaction: when a business interest is at issue, the same retained earnings or cash-flow evidence may affect both property valuation and income analysis; note the doctrinal overlap and the risk of double counting
- Separation-date significance: where the production contains different separation-date references, each date should be preserved with its source because the date can affect marital-period allocation and post-separation spending analysis
- Document-production review practice: a useful exhibit memo identifies what each document shows, what it conflicts with, what it leaves unanswered, and which discovery step best closes the gap
- Controlling-authority practice: when the memo states a legal proposition, identify the governing statute, rule, regulation, or recognized doctrine supporting that proposition rather than leaving it implicit

## 4. Analytical scaffolds

1. Inventory the production first:
   - List each source document by type and date
   - Extract the key figures, account identifiers, dates, counterparties, and narrative statements
   - Note whether the document corroborates, contradicts, or adds to the financial declaration

2. Run a declaration cross-check:
   - Compare income, assets, liabilities, accounts, transfers, distributions, and recurring expenses against the declaration
   - Mark any discrepancy as an omission, contradiction, unexplained variance, or likely supplemental asset source
   - Preserve the exact source document for each flagged point

3. Separate the income-suppression theories:
   - Owner compensation below expected level
   - Business receipts or side income not reflected in the declaration
   - Personal expenses paid by the business or reimbursed without support
   - Retained earnings or undistributed profits
   - Any other recurring income source shown in the production
   - Quantify each category separately before stating the aggregate effect

4. Trace each unexplained balance movement:
   - For each account statement, compare opening and closing balances across the available dates
   - Identify market performance or ordinary activity that may explain part of the change
   - Tie the residual movement to a specific transfer, withdrawal, distribution, or fee if the documents permit
   - If the source set does not resolve the movement, label the gap for follow-up discovery

5. Test for hidden accounts:
   - For every transfer, payment, or funding source, check whether the receiving or sending account appears on the declaration
   - If not, record the institution, account identifier if visible, date, and amount
   - Treat the unexplained account reference as a lead for targeted discovery rather than as a resolved fact

6. Reconcile separation-date references:
   - Enumerate each date reference appearing in the production
   - Preserve the source document for each date
   - State the financial implications of adopting one date over another without overcommitting beyond the record

7. Build the asset summary from the whole set:
   - Real property, bank and brokerage accounts, retirement assets, business interests, vehicles, and any other identifiable property
   - Include estimated value, ownership notes, marital-status note, and source support
   - Distinguish confirmed assets from suspected assets or incomplete leads

8. Tie every issue to action:
   - State the figure or document basis
   - State the related inconsistency or gap
   - State the follow-up step most likely to resolve it

## 5. Vertical / structural / temporal relationships

- Tax returns, K-1s, or similar tax materials can independently test reported income, pass-through allocations, distributions, and wage figures against the declaration
- Credit card statements, reimbursement records, and expense logs can show whether personal charges were pushed through a business entity
- Brokerage statements should be read as time series, not snapshots; interim deposits, withdrawals, and market movement may each explain part of a balance change
- Cover letters, transmittals, or privilege logs may identify missing categories of production or withheld documents that shape the memo’s gap analysis
- Multiple references to the same account or asset across different documents should be linked into one narrative chain rather than reported separately as unrelated items

## 6. Output structure conventions

- Use a single internal memorandum format for the deliverable
- Open with a short purpose statement and a brief note on the source set reviewed
- Include an exhibit catalog organized by document, with each entry showing:
  - document type and date
  - key figures or identifiers extracted
  - cross-reference status against the declaration and other exhibits
  - any inconsistency, omission, or unresolved question
- Follow with an asset summary table grouped by asset category, with source support and a note on whether the asset appears disclosed, undisclosed, or uncertain
- Follow with an issues section that treats each issue as a discrete entry and includes:
  - severity on a consistent ordinal scale defined once near the top
  - source document basis
  - quantified or otherwise scaled significance from the record
  - related document or cross-reference
  - downstream consequence for valuation, support, tracing, or discovery
  - recommended follow-up discovery step
- End with a concise recommended actions block that assigns the next step to the relevant role and ties it to a realistic timing anchor from the case posture or production status
- Where the memo relies on a legal proposition, identify the governing authority by name and cite it in the body rather than stating the proposition abstractly
- Keep the tone internal, practical, and source-driven; do not speculate beyond what the documents support