- Load
~/.claude/plugins/config/claude-for-legal-zh/litigation-legal/CLAUDE.md→ case theory, key facts. - Follow the workflow and reference materials below.
- Extract documents written by or mentioning the witness.
- Build the outline: background, key documents, points relevant to the theory, impeachment materials.
Pretrial Preparation (including trial outline)
Purpose
A pretrial outline is a map: background → lock in favorable facts → confront with unfavorable facts → control scope around the theory. This skill builds that map from the documents and the case theory.
Record Fidelity — Quotations and Precise Citations
Two rules govern every quotation and every citation extracted from the case file into this outline.
Verbatim quotations must be verbatim. Unless you have the exact passage and can cite to it, do not put quotation marks around the words of opposing counsel, a witness, the court, or any case file document. When you want to characterize what someone said but cannot find the exact wording:
- Unquoted paraphrase, with explicit attribution.
- Mark placeholders:
[核实确切引文——案卷引用待定] - Never fill in blanks. A fabricated prior statement destroys impeachment when the witness denies it and the transcript does not support you.
Precise citations must support the entire proposition. If an impeachment point is "the witness said X, Y, and Z on [date]", verify that the precise citation supports X and Y and Z.
Load Context
~/.claude/plugins/config/claude-for-legal-zh/litigation-legal/CLAUDE.md → case theory.
Workflow
Step 1: Who is the witness?
- Name, role, relationship to the case
- Why we need them to testify — what do we need to get from this witness?
Step 1a: Witness posture — fork before drafting questions
The preparation structure differs by posture:
- Opposing/adverse witness— cross-examination style: closed-ended, leading, one fact at a time. Build the frame.
- Own/favorable witness— direct examination style: open-ended questions let the witness tell the story. Using closed-ended leading questions with your own witness is usually inappropriate.
- Neutral third party— mixed; usually open-ended to get the story, closed-ended to lock down specifics.
- Entity party (relevant provisions of the Judicial Interpretation of the Civil Procedure Law)— the entity's legal representative, responsible person, or staff member is questioned on behalf of the entity. Confirm the provisions of the Civil Procedure Law and judicial interpretations regarding party statements.
Step 2: Extract their documents
From the case materials:
- Documents written by the witness
- Documents sent to or by the witness
- Documents mentioning the witness's name
- Minutes of meetings the witness attended
Step 3: Build the points
Each point is a matter you want to establish or explore. Organize around the theory:
Background (always first — lock in undisputed facts before the witness becomes defensive):
- Role, tenure, duties
- Reporting relationships
- How they interact with key participants
Favorable facts (lock in before confrontation):
- Facts this witness can establish that support your theory
- Documents the witness wrote or received that support your theory
Unfavorable facts (confront with documents):
- Facts unfavorable to your side that the other side will ask about no matter what—get your version first
- Damaging documents—know how the witness will explain them
Impeachment material (such as from the other side or if inconsistencies exist):
- Prior inconsistent statements (from documents, prior testimony, written statements)
- Documents that contradict what you expect them to say
Core facts:
- A sequence of questions that establishes (or undermines) the facts the case depends on
Step 4: Write the outline
[工作成果标题]
# 庭前准备提纲：[证人姓名]
**证人角色：** [头衔、与案件的关系]
**证人立场：** [对方 / 己方 / 中立] —— 驱动问题形式
**为何需要此证人作证：** [一句话——目标]
**理论联系：** [该证人如何适应案件理论]
---
## 一、背景
[问题——锁定无争议内容]
## 二、[有利事实主题]
**目标：** 确立 [事实]。
**文件：**
- [证据编号] —— [描述] —— [为何重要]
**问题：**
[序列。构建至关键确认。]
## 三、[不利事实主题]
**目标：** 在我方条件下获取证人对 [不利事实] 的解释。
[相同结构]
## 四、质证材料（如需要则使用）
[如证人矛盾时用于对质的先前陈述/文件]
## 五、[核心事实序列]
**目标：** [案件依赖于的事实]
---
## 证据列表
| # | 证据编号 | 描述 | 用于章节 |
|---|---|---|---|
## 给律师的备注
- [提纲未捕获的任何内容]
What this skill does not do
- Conduct a pretrial conference or trial. The outline is the map; the lawyer drives.
- Predict what the witness will say. It prepares possible answers, but witnesses surprise you.
- Decide what to ask at trial. Follow-up questions are the lawyer's judgment in the moment.