Claude skill 03 · deposition-compare
Deposition compare
Analyze and compare the depositions of several witnesses in a medical-device matter — who said what on each fact and topic, where the witnesses agree, where they differ, where each one contradicts the documents, how the event looks from each witness's position, what nobody was asked, and what the next witness should be asked — every statement cited to a witness, page, and line. Works from the testimony databases the deposition-summary skill builds (or builds them first).
SKILL.md
The instructions, as Claude reads them.
One folder, one file. Download the .skill file and add it in Claude’s skills settings, or unzip it into your skills folder. Our guide 06 explains the method and its limits.
The skill states what the records say and where. It does not form opinions on cause or liability. Check every citation before a document leaves your team.
One witness gives an account. Several witnesses give a set of accounts that overlap, differ, and leave holes between them, and the differences are where a matter turns. This skill lays the accounts side by side, fact by fact, so the team can see for each point who said it, who said otherwise, who was never asked, and what the documents say. It states the differences; it does not decide who is right.
1. Inputs
- The testimony databases:
depositions/<witness>-testimony.csvfor each witness, withdepositions/index.csv, as thedeposition-summaryskill writes them. If a transcript has no database yet, run that skill on it first; never compare from the summaries alone, and never from memory of a transcript. - The archive (
case-brief): to check statements against documents and to cite them. - The matter's topic list (
topics.mdfrom the summaries, merged): one list for all witnesses. Where two summaries used different topic names for the same thing, map them once intopic-map.csvand use the merged names everywhere. - The question, when the user has one: a date, a decision, an alarm, a conversation. The comparison then starts there and widens; without one, it covers every topic that two or more witnesses reached.
2. Build the fact matrix
The unit of comparison is a fact: a short, neutral proposition that a witness could affirm, deny, qualify, or not know ("the alarm sounded before the pump stopped"; "the service visit on March 4 included a software update"; "the risk file was reviewed after the first complaint"). Facts come from the testimony rows, not from the pleadings.
- Collect from all databases the rows under each merged topic. Read them together, witness by witness.
- Write the facts: for each point two or more witnesses addressed, one line in
facts.csv:fact id·topic·fact(neutral proposition) ·document evidence(what the archive says, with[D-0042 p.7], ornone foundwith the search terms) ·note. - Fill the matrix:
matrix.csv, one row per fact, one column per witness, each cell one code with its cite: Aaffirms —A [Smith 44:12–45:3]Ddenies —D [Jones 102:7–11]Qaffirms with a qualification —Q [Lee 77:1–9] (only "to my knowledge")Eestimates or is unsure —E [Lee 80:2–6] ("probably", "I think")Kdoes not know —K [Smith 50:3]Rdoes not recall —R [Jones 110:14]Nnot askedXinstructed not to answer / objection, no answer Plus adocumentscolumn with the same codes for the archive (A [D-0042 p.7],D [D-0051 p.2],none), and astatuscolumn:agree(all who answered gave the same code),differ(A against D or Q),uncertain(only E/K/R),one witness(only one answered),untested(all N).
The matrix is the product. Everything after it is a reading of it.
3. Find what the matrix shows
Work through the matrix and write the findings into tables, each line cited:
- Differences (
differrows): the fact, each witness's position with the verbatim words, the document evidence, and the nature of the difference — a different date, a different actor, a different sequence, presence against absence, knowledge against no knowledge. Order them by the weight of the fact in the matter (the user's question first). - Witness against document: every cell where a witness's code differs from the documents column. Cite both. Say what the document is (a contemporaneous log, a later report, an email) so the reader knows what kind of evidence it is.
- Internal shifts: a witness who gave two different answers on one fact (the summaries flag these; collect them here with both cites).
- Agreement:
agreerows, briefly; counsel needs to know what is settled as much as what is open. - Vantage points: for the event itself, a short table of where each witness was, what they could see or hear, and from when to when, each cell cited. A difference between two witnesses who stood in different places is a different kind of difference from one between two who stood together.
- Knowledge and time (manufacturer or hospital witnesses): for each fact about a problem being known, who said they knew, when, from what, with cites, in date order — the raw material for the
device-timelineskill's knowledge dates. - Not asked:
untestedandone witnessrows, grouped by topic; and the facts that only one side's counsel explored.
4. Verify
- Every cell cite opened against the testimony row and, for
keyrows, against the transcript page. A cell with a wrong cite is a wrong finding. - Every
differrow read again in full context (the question, the answer, three lines each side). A difference that disappears when the question is read is not a difference; delete it. - Every document cite opened.
- The fact wording checked for neutrality: if a fact reads as one side's theory, rewrite it until both sides would accept it as the thing in dispute.
5. Write the output
comparison.md:
- Scope: witnesses compared (name, role, date, pages), databases and archive used, the question if there was one, merged topic list.
- In one page: the ten to fifteen differences that matter most, each in two or three lines with cites, and the facts on which the witnesses agree.
- The matrix, by topic, as tables (
fact· one column per witness · documents · status). Codes with cites; verbatim words in a footnote line under the row when they carry the difference. - Differences in detail: one short section per
differrow of weight: the fact, each account in the witness's words, the documents, the nature of the difference. - Witnesses against the documents.
- Vantage points and Knowledge and time tables.
- Not asked, and questions for the next witness: by topic, written as questions, with the witness for whom each is intended and the cite that prompts it.
- Sources.
Beside it: facts.csv, matrix.csv, topic-map.csv, differences.csv (fact id · witnesses · codes · cites · document evidence · nature), questions-next.csv (topic · question · for whom · prompted by).
Citation form: [Lastname 112:4–113:2] for testimony inside this document, [Depo Lastname 112:4–113:2] in anything that leaves it; [D-0042 p.7] or Bates for documents.
6. Refreshing
When a new deposition is taken: run deposition-summary on it, add its column to the matrix, re-run sections 3 to 5, and open comparison.md with a What changed section — facts the new witness affirmed, denied, or moved from one witness to agree or differ; questions from the previous Not asked list that were now asked, with the answers.
7. Rules
- Compare databases, not memories, and not summaries alone.
- A fact is neutral or it is rewritten.
- One code and one cite per cell; verbatim words where the difference lives in the words.
- A difference survives only if it survives the full context.
- No judgment of credibility, truthfulness, or motive, and no conclusion about which account is correct. The matrix shows the accounts and the documents; counsel and the finder of fact decide.
- Say what was not asked. The holes are findings.
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