casemark/expert-deposition
skills/legal/expert-deposition/SKILL.md
Guides taking or defending U.S. expert witness depositions with Daubert/Frye methodology testing, Rule 26(a)(2) compliance, and Rule 702/703 foundations. Use when building expert deposition outlines, preparing Daubert challenge records, defending expert prep sessions, reviewing expert reports for admissibility, or creating expert testimony lock-in strategies.
$ install --global
skillsauthnpx skillsauth add casemark/skills expert-depositionInstall this skill globally with one command. Works with Claude Code, Cursor, and Windsurf.
Security Scan Results
3 of 9 scanners reported clean
Some scanners were skipped, did not run, or reported a non-clean status. Review each row below.
3
Scanners Passed
9
Scanners in report
Clean
TrivyContainer and dependency vulnerability scanner
95%
Clean
SemgrepStatic code analysis for vulnerabilities
95%
Clean
mcp-scan (Snyk)Model Context Protocol security validation
95%
Skipped
Snyk (dep)Open source security scanning
50%
Skipped
Socket.devSupply chain security analysis
50%
Skipped
VirusTotalMulti-engine malware detection
50%
Skipped
CrowdStrikeAdvanced threat intelligence
50%
Skipped
OSV-ScannerOpen Source Vulnerability database check
50%
Skipped
OWASP Dep-Check
50%
Last scanned: Aug 8, 2026, 4:12 AM306.7s1 file scanned
SKILL.md
- name:
- expert-deposition
- language:
- en
- description:
- Guides taking or defending U.S. expert witness depositions with Daubert/Frye methodology testing, Rule 26(a)(2) compliance, and Rule 702/703 foundations. Use when building expert deposition outlines, preparing Daubert challenge records, defending expert prep sessions, reviewing expert reports for admissibility, or creating expert testimony lock-in strategies.
Expert Witness Deposition
Builds a motion-ready expert deposition record or defense-prep plan targeting Daubert/Frye admissibility. Covers qualification limits, methodology attacks, bias/compensation exposure, and opinion lock-in.
Prerequisites
- Venue admissibility standard (Daubert, Frye, or state hybrid) and local expert disclosure rules
- Rule 26(a)(2) expert report(s) and disclosure materials
- Expert CV, publications, and prior testimony list
- Case facts and key documents (reviewed and not reviewed by expert)
- Alternative theories, critiques, or rebuttal materials
Quick Start
Begin every expert deposition task with an intake snapshot:
| Field | Detail | |---|---| | Jurisdiction | Federal/State, Daubert/Frye, local rules | | Expert | Name, field, retention side, role | | Opinions | Enumerated list from report | | Methodology | Methods, standards, tools, testing | | Materials | Documents reviewed, gaps, assumed facts | | Bias | Compensation, retention history, firm ties |
Then choose the appropriate workflow: Taking (Deliverable A) or Defending (Deliverable B).
Deliverable A: Taking Expert Deposition
Outline Structure
I. Qualifications and Boundaries
II. Engagement, Scope, and Compensation
III. Materials Reviewed and Assumptions
IV. Methodology and Reliability
V. Each Opinion (state, basis, certainty)
VI. Application to Case Facts
VII. Prior Testimony and Publications
VIII.Lock-In and Completeness
Question Bank
| Topic | Objective | Key Lines | |---|---|---| | Qualifications | Define limits | "Expertise is X, not Y?" / "How recent is hands-on work?" | | Engagement/Bias | Expose incentives | "Rate?" / "Percent income from litigation?" / "Prior exclusions?" | | Materials | Show gaps | "What did you review?" / "Did you see [critical doc]?" / "Independent investigation?" | | Methodology | Build Daubert record | "Tested? Peer-reviewed? Error rate?" / "Governing standards?" / "Alternatives considered?" | | Opinions | Lock in | "State opinion precisely." / "Basis and data?" / "Degree of certainty?" | | Application | Test fit | "Inputs used?" / "If X fact wrong, opinion changes?" | | Impeachment | Show inconsistency | "In [case/publication] you said ___?" / "What changed?" |
Lock-In Questions
Always close with:
- "Are those all opinions you intend to offer?"
- "Any opinions not in your report?"
- "Any bases not stated in your report?"
Daubert/Frye Record Checklist
Flag each ground that applies:
- [ ] Qualifications limited in relevant sub-field
- [ ] Method not testable or not tested
- [ ] No peer review or publication
- [ ] Error rate unknown or unacceptable
- [ ] No governing standards or standards not followed
- [ ] Not generally accepted in the field (Frye)
- [ ] Unreliable application to case facts
- [ ] Insufficient facts/data or unverified assumptions
- [ ] Failure to consider contrary evidence
- [ ] Opinion not helpful to trier of fact (Rule 702)
Deliverable B: Defending Expert Deposition
Preparation Sessions
| Session | Goal | Materials | |---|---|---| | Report Mastery | Clear explanation of each opinion | Final report, exhibits | | Methodology Defense | Articulate reliability and fit | Standards, literature, calculations | | Mock Deposition | Practice hostile questioning | Prior testimony, publications |
Coaching Points
- Explain, don't advocate
- Stay within expertise boundaries
- Acknowledge limitations without overstating certainty
- Plain language a jury can follow
- Separate counsel-provided facts from independent analysis
Work Product Boundaries (FRCP 26)
| Protected | Discoverable | |---|---| | Draft reports (26(b)(4)(B)) | Facts/data considered | | Attorney-expert draft opinion communications (26(b)(4)(C)) | Assumptions from counsel | | Attorney mental impressions | Compensation terms |
Objection Guide
- "Objection, work product" for draft report inquiries
- "Objection, attorney-client privilege" when applicable
- Preserve objections but allow testimony on facts/data considered
Pitfalls
- Wrong standard: Confirm Daubert vs. Frye vs. hybrid before drafting; methodology attack differs significantly.
- Opinions beyond report: Do not allow undisclosed opinions unless strategically beneficial; force explicit lock-in.
- Evasive coaching: Credibility depends on clarity and candor; never coach experts to evade.
- Privilege waiver: Preserve work-product and privilege objections while allowing proper discovery into facts/data and assumptions.
- Jurisdictional variance: Flag local differences in expert disclosure scope and deposition time limits.
Key Authorities
FRCP 26(a)(2), 26(b)(4) | FRE 702-703 | Daubert v. Merrell Dow | General Electric v. Joiner | Kumho Tire v. Carmichael | Frye v. United States
Related Skills
casemark/medical-records-gap-analysis
tools
VerifiedTrustedCommunity
Audits the complete in-scope medical-record universe in a litigation matter and produces an attorney-facing, Bates-cited analysis of treatment gaps, missing records or providers, baseline coverage, material billing or production mismatches, and complaint evolution. Use when asked to find missing medical records, analyze treatment gaps or first-care timing, identify absent providers, assess whether a production is complete, or prepare a records-request target list. Use medical-record-chronology instead when the primary request is a chronological clinical narrative.
40SKILL.mdUpdated Sep 3, 2026
casemark/private-placement-memo
development
VerifiedTrustedCommunity
Drafts a legally compliant Private Placement Memorandum for Regulation D offerings (Rule 506(b)/506(c)), covering full disclosure framework including risk factors, capitalization, securities terms, use of proceeds, and investor qualification requirements. Enforces SEC anti-fraud compliance under Section 10(b)/Rule 10b-5, blue sky law considerations, and accredited investor verification under Rule 501. Use this skill when drafting PPMs, offering memorandums, Reg D disclosure documents, or private offering circulars for issuers raising capital from sophisticated investors. Also trigger when the user mentions private placement disclosure, offering memorandum, Reg D fundraising, or accredited investor verification. Even if the user just says "PPM" or "draft our offering memo," use this skill.
40SKILL.mdUpdated Apr 17, 2026
casemark/privacy-law-updates
data-ai
VerifiedTrustedCommunity
Generates structured privacy and data protection law briefings across US, EU, UK, and other jurisdictions. Organizes by jurisdiction with compliance deadlines, enforcement actions, and legislative changes. Use when preparing privacy law briefings, compliance updates, regulatory change summaries, or data protection landscape reviews.
40SKILL.mdUpdated Apr 17, 2026
casemark/prior-art-summary
testing
VerifiedTrustedCommunity
Generates structured summaries of prior art references for patent prosecution, validity analysis, and freedom-to-operate assessments. Maps disclosures to claim elements with precise citations. Use when summarizing prior art, analyzing patent landscapes, mapping references to claims, or preparing office action responses.
40SKILL.mdUpdated Apr 17, 2026