Chronology

/chronology

1. Load ~/.codebuddy/plugins/config/legal-workflows/litigation-legal/matters/[slug]/matter.md → theory, pivot fact, key facts.
2. Load ~/.codebuddy/plugins/config/legal-workflows/litigation-legal/practice-profile.md → Document storage sources, default matter folder pattern.
3. Follow the workflow and reference below.
4. Identify sources in order: user-provided paths this session, default matter folder, declared sources from ~/.codebuddy/plugins/config/legal-workflows/litigation-legal/practice-profile.md.
5. For readable sources: extract dated events. For unreachable sources: note in Gaps.
6. De-dupe, merge with sources list per event.
7. Tag significance (🔴/🟡/⚪) per matter theory.
8. Write ~/.codebuddy/plugins/config/legal-workflows/litigation-legal/matters/[slug]/chronology.md (or format variant per flag).
9. If prior version exists: version number increments, diff summary presented to user.
10. Confirm before finalizing: "Here's what I built. Scan the 🔴 entries — anything I miscalled?"

Chronology

Disclosed-document use restrictions

Before working with a set of litigation documents, ask: "Were any of these documents obtained through disclosure or evidence exchange in legal proceedings?" If yes:

• England & Wales (CPR 31.22): Documents obtained through disclosure are subject to the implied undertaking — you may only use them for the purpose of the proceedings in which they were disclosed, unless the court grants permission, the disclosing party consents, or the document has been read in open court. Using them for a different matter, a different claim, or a commercial purpose without permission is a contempt.
• US: Protective orders and Rule 26(c) may impose similar restrictions. Check the order.
• Other jurisdictions: Similar restrictions commonly apply. Check the local rule.

Confirm: "This use is within the proceedings in which the documents were disclosed, or I have permission / consent, or the documents are now public." If not confirmed, flag it: "⚠️ Disclosed documents may have use restrictions. Confirm this use is permitted before proceeding."

Purpose

Facts happen in order. The chronology is the spine every narrative hangs on — the statement of facts in a brief, reserve memos, settlement memos, witness interview prep, witness prep. Building a chron by hand is slow; AI is good at structured extraction. The catch: garbage-in, garbage-out. This skill pulls from the sources the configuration declares and from whatever the user uploads.

Modes

This skill serves two practice settings. Pick a default from the user's ## Role in the plugin's configuration practice-profile.md; the user can override per-run with a flag.

• --matter mode (default for in-house litigation counsel). Matter-history-focused. Reads the matter's case theory and key facts from matter.md, pulls from declared document-storage sources (Google Drive, SharePoint, Gmail, iManage, CLM — whatever the ## Landscape section of practice-profile.md declares), and treats history.md as the running internal log (decisions, holds, reserve memos — intentionally not in the chronology). Output is matter-centric: what happened across the dispute, tagged for advocacy use.
• --documents mode (default for firm associate / paralegal). Production-document-focused. Reads the case theory from the configuration, then extracts from an document review export, a custodial file set, or a Bates-numbered production. Output is production-centric: what the documents show, with Bates citations, tagged per the case theory.

Both modes converge on the same output structure (timeline, 🔴/🟡/⚪ significance tags, gaps, SoF variant). The difference is the source profile and the significance frame.

If ## Role is solo or other, default to --matter but mention both modes on the first run and let the user pick.

Side framing (significance tags)

The same event is significant in different ways depending on whether the practitioner is proving a claim or disproving it. Read ## Side in the practice profile (and the per-matter posture if the matter overrides the default):

• Plaintiff (offensive framing) — 🔴 marks events that establish elements of the claim (liability, causation, damages, notice), close gaps the defense will try to open, or start statute-of-limitations clocks in the plaintiff's favor. 🟡 marks events that support the claim but are subject to impeachment. ⚪ is background context.
• Defense (defensive framing) — 🔴 marks events that break elements of the claim (failure of causation, notice, reliance), open statute-of-limitations or jurisdictional defenses, or support affirmative defenses (release, waiver, assumption of risk, comparative fault). 🟡 marks events that undermine the plaintiff's narrative. ⚪ is background.
• Both / varies — ask the user per-chronology which side's framing to apply for significance tags. The underlying timeline is side-neutral; only the significance read changes.

Note the applied framing at the top of the output: Significance tags applied from [plaintiff / defense] perspective. When producing a Statement of Facts variant, use the side default unless the user specifies otherwise.

Load context

Common:

• Plugin configuration practice-profile.md → case theory context (in-house: ## Landscape for document sources; firm associate: ## Case theory and ## Document review for platform + custodians), ## Outputs for the work-product header, ## Decision posture for the privilege-flagging rule.
• Prior chronology.md for this matter, if it exists.
• Any files the user uploads or paths they provide in-session.

--matter mode also reads:

• ~/.codebuddy/plugins/config/legal-workflows/litigation-legal/matters/[slug]/matter.md → case theory, key facts, pivot fact (for significance tagging), key dates.
• Default matter folder pattern from practice-profile.md → where docs for this slug live.

--documents mode also reads:

• document review platform metadata if a connector is available (document-review platform, Relativity, DISCO, Aurora) — by custodian + date range.
• Bates-range manifest or production index if the user points at one.

Conflicts gate — unbypassable (--matter mode). Before building the chronology, check ~/.codebuddy/plugins/config/legal-workflows/litigation-legal/matters/_log.yaml for the matter slug. If the matter is not in _log.yaml, refuse and route:

"I don't see [matter slug] in the matter log. Run /litigation-legal:matter-intake first so the conflicts check runs and the matter workspace is set up. I won't build a chronology on a matter that hasn't been intaken — the conflicts check is the gate."

Do not proceed on an unintaken matter. Intake is what runs conflicts and writes the _log.yaml row this skill reads from. --documents mode (running against an ad-hoc document set without a matter slug) is exempt from the gate, but its outputs should be treated as pre-matter research and not filed as if matter work product.

Workflow

Step 0: Privilege gate (runs first, every time)

Chronology work pulls from documents. Documents are often privileged (attorney-client, work product, common interest, joint defense) — in-house matter files often are by default; document review productions, especially rolling productions or common-interest productions, often contain privileged or unreviewed material. Extracting content from a privileged document into a chronology that later gets shared can risk waiver, depending on who receives it and under what doctrine (common-interest, joint-defense, Kovel, and work-product protections may apply). Waiver analysis is fact-specific — get counsel sign-off before distributing.

The skill will not extract until the user picks a confidentiality posture:

Before I extract: how have the sources been privilege-screened?

• A. All sources cleared — you've already screened these. I extract without privilege flags. Output is evidence exchange-ready posture; still marked work product.

• B. Mixed or not yet screened — I extract and tag every entry with a priv flag: ok (sourced from clearly non-privileged material), flag (sourced from potentially privileged material — A/C, WP, common interest), or review (source unclear). Flagged entries are visually marked in the output, and the Statement-of-Facts variant filters them out by default.

• C. Abort — screen first — pause the skill. Screen the sources. Return and re-run.

Record the choice in the chronology header as privilege_posture: A-cleared | B-mixed | C-aborted. If B or C, record the rationale briefly.

Why a gate and not just a warning: a warning gets read once and forgotten. A gate forces the posture decision into the record, which means every chronology file carries its own provenance — anyone reading it later knows whether entries were derived from privilege-screened material.

Step 1: Identify document sources

--matter mode:

1. User-provided paths — anything dropped in this session (file paths, drive links, email exports).
2. Default matter folder — from practice-profile.md's document-storage pattern, expanded for this slug (e.g., G:/Legal/Matters/acme-v-us-2026).
3. Declared sources — the Document storage table in practice-profile.md, filtered to ones this matter might touch (e.g., Gmail archive for sender-side communications, SharePoint legal folder).
4. Ask — if sources look thin, prompt: "I can build from what I have, but the chronology will be incomplete. Anything else to point me at? Key emails, contracts, internal memos, production letters?"

--documents mode:

1. Production export / Bates set — the user points at the production directory or a manifest; the skill reads by Bates range + date.
2. document review connector — if an MCP connector is available (document-review platform, Relativity, DISCO, Aurora), pull by custodian + date range.
3. Custodial files — if the user provides raw custodial mailboxes or drive exports, read those too.
4. Ask — if coverage looks thin for a key custodian or date range, prompt.

Step 2: Pull + read

For each source with readable files:

• PDFs, emails (.eml), .docx, .txt — read directly.
• Email archives (Gmail, Outlook) — if an MCP connector is authenticated, query by date range + counterparty / key terms; otherwise the user exports relevant threads to a folder.
• document review platforms (document-review platform, Relativity, DISCO, Aurora) — if connector is available, pull by custodian + date range; otherwise the user provides an export.

If the skill can't access a declared source, name it explicitly in the output's Gaps section rather than silently proceeding.

No silent supplement. If source coverage for an era of the matter is thin — fewer documents than expected for a claimed time window, a custodian whose mailbox isn't accessible, a production that hasn't landed — report what was found and stop. Do NOT fill gaps from web search, public record search, or model knowledge about the matter without asking. Say: "Sources returned [N] events for [period / custodian]. Coverage appears thin. Options: (1) point me at additional sources (Bates, folder, mailbox), (2) try a different MCP connector if configured, (3) search the web for public-record events in this window — results will be tagged [web search — verify] and should be checked against a primary source before relying, or (4) stop here and note the gap. Which would you like?" A lawyer decides whether to accept lower-confidence sources; the skill does not decide for them.

Source attribution. Tag every chronology entry with where the event came from: the file path, Bates number, MCP connector, or declared document-storage source for events extracted from retrieved documents (already captured in the Sources column). For any event or date that cannot be traced to a retrieved document — e.g., a fact recalled from model training data, a public-record event found via web search — tag it inline: [web search — verify], [model knowledge — verify], or [user provided] where the user stated the fact in-session. Entries tagged verify carry higher fabrication risk than document-sourced entries and should be checked first. Never strip or collapse the tags — they are counsel's fastest signal about which entries to verify before pulling them into a brief or SoF.

Tagging reaches every section that states a legal conclusion, deadline, or computed date — not just timeline entries. The timeline is sourced from documents. The Gaps section, the Key events section, the Theory tie lines, and any statement of limitations, tolling event, filing deadline, evidence exchange cutoff, or privilege determination are legal analysis the skill writes from model knowledge unless sourced. Every such statement carries a provenance tag: [computed from: <rule cited with tag>], [model knowledge — verify], [user provided], or a research-connector tag if retrieved in this session. A statute-of-limitations window with no tag defaults to [model knowledge — verify]. A "key event" line that characterizes a fact's legal significance is analysis and needs the tag. The rule is simple: if it's an assertion about the law, not an assertion about what a document says, it must carry the same provenance tag the timeline entries do. When no research connector is reachable and the skill is computing deadlines or citing rules, record it in the Sources: line of the reviewer note (see plugin practice-profile.md ## Outputs) — do not emit a standalone banner.

Step 3: Extract events

For each document, identify dated events:

• Email: [date] [sender] told [recipient] [subject/content]
• Meeting: [date] [attendees] met about [topic] (per calendar entry or notes)
• Decision: [date] [decision-maker] decided [what] (per memorializing doc)
• Filing / pleading: [date] [party] filed [motion/complaint/response]
• External event: [date] [thing happened] (contract signed, product launched, regulator acted, event crossed a threshold)

One event per document usually. Occasionally zero (undated or no event established). Sometimes multiple (meeting summary covering several decisions).

Privilege flag per entry (only when privilege_posture == B-mixed). Three-state rule — never silently decide a subjective privilege test isn't met:

• priv: ok — source is confidently non-privileged (filings, regulatory correspondence, public docs, counterparty communications without our counsel). Used only when there's no plausible privilege theory.
• priv: flag — source is confidently or likely privileged (communications with counsel, work-product memos, privileged drafts, joint-defense material). Default for anything uncertain — if the dominant-purpose call is close, or litigation contemplation is borderline, or the content is mixed, it goes here, not in ok.
• priv: review — source unclear on its face, but the skill could not make the call at all (no sender/recipient metadata, unreadable, etc.).

When priv: flag or priv: review, add [SME VERIFY: privilege status] inline so the counsel sees it during review. Under-flagging waives privilege (one-way door); over-flagging is corrected by counsel in review (two-way door). Prefer the recoverable error.

Step 4: De-dupe

The same event surfaces in multiple documents: a meeting is on three calendars and produces a summary email — that's one event with four sources, not four events. Merge. The merged entry cites all sources.

Step 5: Tag significance — per case theory

Read the pivot fact and key facts from matter.md (--matter mode) or from the configuration's ## Case theory section (--documents mode). Tag each event:

• 🔴 Key — event is part of the pivot fact or a key fact for/against us
• 🟡 Relevant — context, pattern evidence, supports a secondary argument
• ⚪ Background — useful for completeness, not going in the brief

Discipline: a chronology of 300 entries with 300 🔴 tags has no tags. Reserve 🔴 for events that would genuinely move a factfinder. If in doubt, 🟡.

Borderline tagging: when an entry sits between 🔴 and 🟡 (or 🟡 and ⚪), tag at the lower significance and add [SME VERIFY — borderline significance call] inline. Counsel's judgment will override the skill's call. A chronology that confidently over-tags is less useful than one that surfaces its uncertainty.

Step 6: Write

Default output is the working chronology. Variants on request.

Output formats

Working chronology (default)

Location: ~/.codebuddy/plugins/config/legal-workflows/litigation-legal/matters/[slug]/chronology.md. Complete, tagged, annotated. The reference doc counsel works from.

[WORK-PRODUCT HEADER — per plugin config ## Outputs — differs by role; see `## Who's using this`]

> **Privilege inheritance.** This chronology is derived from matter documents that may be attorney-client-privileged, work-product-protected, common-interest / joint-defense material, or a mix. It inherits the sources' protection status. Distributing it beyond the privilege circle — to business stakeholders outside the engagement, to opposing counsel, to a regulator — can waive protection over both the chronology and the underlying sources. Store with privileged matter material, mark consistently with house privilege conventions, and make distribution decisions deliberately. The privilege-posture choice captured below is the provenance stamp for any later distribution call.

# Chronology — [Matter Name]

> Significance tags (🔴/🟡/⚪) and privilege flags (🔒) are first-pass reads requiring `[SME VERIFY]` before use in any external work product (briefs, SoF, board memo, outside counsel deliverable).

**Matter:** [slug]
**Mode:** matter | documents
**Built:** [YYYY-MM-DD]
**Sources:** [N] documents across [source types]
**Entries:** [N] ([N] 🔴 / [N] 🟡 / [N] ⚪)
**Pivot fact:** [one sentence]
**Privilege posture:** A-cleared | B-mixed | C-aborted
**Flagged entries:** [N] 🔒 *(only present when posture == B-mixed)*

---

## Timeline

| Date | Event | Tag | 🔒 | Sources |
|---|---|---|---|---|
| [YYYY-MM-DD] | [what happened, one sentence] | 🔴/🟡/⚪ | [blank / 🔒-flag / 🔒-review] | [file paths or Bates] |

---

## Key events (🔴 only)

[Pulled out, each with a line on why it matters to the theory.]

### [date] — [event title]
- What: [one line]
- Theory tie: [why this matters]
- Sources: [list]

---

## Gaps

**Date ranges with no events:**
[ranges — where are documents for this period?]

**Expected but missing:**
[events we'd expect to see documented but don't — e.g., "contract amendments between 2024-06 and 2025-03 — not produced"]

**Unreadable sources:**
[sources declared in practice-profile.md but not accessible this run — e.g., "document-review platform production — no MCP connector; export needed"]

---

## Marker discipline

- `[VERIFY: factual assertion — date, attendees, content]` — not yet confirmed against the underlying doc
- `[UNCERTAIN: legal characterization — e.g., whether an event establishes a regulatory trigger]`
- `[CITE NEEDED: Bates / exhibit / witness interview page:line]`
- `[SME VERIFY: privilege status | borderline significance call]` — counsel judgment needed

---

## Version
- v[N] built on [date] from [source summary]
- v[N-1] built on [date] (prior, superseded)

Statement-of-facts chronology (on request)

Filter to 🔴 and relevant 🟡 only. Present as prose in chronological narrative order — the skeleton for a brief's fact section. Each paragraph is one event or tightly linked cluster, with record citations.

Privilege filter default: when privilege_posture == B-mixed, 🔒-flagged and 🔒-review entries are excluded by default. The SoF variant is intended for eventual external use (briefs, disclosures, negotiating counterparty) — 🔒 entries don't belong there until counsel confirms privilege status. If the user wants 🔒 entries included anyway, require explicit --include-flagged acknowledgment; capture the acknowledgment in the output header as permanent record.

Witness-specific chronology (on request)

Filter to events where a named witness is sender, recipient, attendee, or subject. Feeds witness prep and helps reconstruct what a witness knew when.

Incremental builds

If chronology.md exists:

• Read prior version
• Build new chronology from current sources
• Diff: new events (since last build), modified entries (new sources added to existing events), removed entries (rare; note why)
• Preserve the prior version number; write new version with v[N+1]
• Output summary of what changed

Integration with matter.md / history.md

Intentionally separate (in-house --matter mode). history.md is counsel's running log — decisions, updates, procedural milestones, internal strategy notes. chronology.md is the advocacy-facing timeline of facts. They overlap but don't merge:

• A hold was issued → goes in history.md (internal action). Usually not in chronology (not a fact of the dispute).
• The counterparty sent a breach notice on March 14 → goes in chronology.md (🟡 — establishes their knowledge). Also in history.md if the intake referenced it.
• Our reserve recommendation memo was drafted → history.md only.

When counsel wants history events in the chronology, they can paste them. The default is they stay separate.

What this skill does not do

• Resolve contradictions. When two documents say different things about when an event happened, both entries go in with a flag. Resolution is counsel's call; may require witness interview or further evidence exchange.
• Invent events not in the sources. If it's not in the documents (and not in matter.md or the configuration as a captured fact), it's not in the chronology — but "Gaps" might call it out as missing.
• Guarantee completeness. A chronology is only as good as the sources. If the document review production is ongoing and only 20% has landed, the chronology reflects that. Name the limitation.
• Decide privilege status for the user. The Step 0 gate forces the posture choice; the per-entry priv flag captures first-pass classification. Actual privilege determinations are counsel's call per [SME VERIFY] flags.