ceo-orchestration 1.0.0

package/.claude/skills/domains/legal/skills/legal-billing/SKILL.md

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+---
+name: legal-billing
+description: |
+  Legal billing and time-tracking discipline for law firms and legal
+  departments. Covers billable vs. non-billable classification, ABA Model Rule
+  1.5 reasonableness factors, contemporaneous time entry requirements, UTBMS
+  task-code mapping for litigation, expense pass-throughs, retainer lifecycle
+  (true / replenishing / evergreen), trust and IOLTA client-funds segregation,
+  jurisdictional fee-rule compliance (US state bars, EU bar associations, OAB
+  Brazil), and billing anti-pattern detection. PII-touching: client matter
+  data, adversary information, privileged communications, and work product are
+  all personal or confidential data subject to legal professional privilege and
+  data-protection law. Use when: classifying time entries for a matter invoice;
+  reviewing trust account reconciliation; advising on fee arrangement structure;
+  auditing billing narratives for ABA compliance; applying LGPD Art. 11
+  controls to legal-sector data; or vetting expense pass-through ethics.
+owner: Valentina Moreira (Legal Billing Specialist, domain persona)
+tier: domain:legal
+scope_tags: [legal-billing, time-tracking, billable-hours, trust-accounting, iolta, fee-rules]
+inherits: [core/compliance-lgpd, core/pii-data-flow, core/consent-lifecycle, core/dpo-reporting]
+pii_handling: required
+inspired_by:
+  - source: msitarzewski/agency-agents/specialized/legal-billing-time-tracking.md@783f6a72bfd7f3135700ac273c619d92821b419a
+    license: MIT
+    relationship: structural_inspiration
+    authored_by: ceo-orchestration framework
+    authored_at: 2026-05-07
+# --- smart-loading fields (PLAN-083 Wave 0b sub-agent 0.7c) ---
+domain: legal
+priority: 5
+risk_class: medium
+stack: []
+context_budget_tokens: 600
+inactive_but_retained: false
+repo_profile_binding:
+  frontend: {active: false, priority: 10}
+  engine: {active: false, priority: 10}
+  fintech: {active: true, priority: 7}
+  trading-readonly: {active: false, priority: 10}
+  generic: {active: false, priority: 10}
+activation_triggers: []
+# --- K1 paths: native file-touch activation (PLAN-135 W3 unit k1a) ---
+paths:
+  - "**/billing/**"
+  - "**/time-entries/**"
+  - "**/invoices/**"
+  - "**/trust-accounts/**"
+  - "**/retainers/**"
+---
+
+# Legal Billing
+
+## Cardinal Rule
+
+Every time entry, invoice, and trust transaction must be accurate, honest, and
+contemporaneous. ABA Model Rule 1.5 requires fees to be reasonable; Rule 1.15
+requires client funds to be held inviolate. Neither rule admits exceptions for
+administrative convenience, workload pressure, or revenue targets. A billing
+decision that cannot survive bar disciplinary scrutiny must not be made.
+
+## Fail-Fast Rule
+
+Stop and escalate to the responsible attorney when any of the following is
+detected:
+
+- A time entry is being reconstructed from memory more than seven days after
+  the work was performed — label it estimated-reconstruction and flag for
+  attorney review before invoicing.
+- A trust account disbursement would produce a negative client-ledger balance
+  — reject and require source-of-funds clarification first.
+- Block billing appears on a matter whose client guidelines explicitly prohibit
+  it — hold the invoice and require entry decomposition.
+- A fee agreement for a contingency arrangement is not confirmed in writing
+  before the matter proceeds — oral contingency arrangements are unenforceable
+  in most jurisdictions.
+- Personally identifiable data from a client matter is being transmitted,
+  stored, or shared outside encrypted channels — halt and apply the PII
+  controls below before proceeding.
+
+## When to Apply
+
+Apply this skill when:
+
+- Classifying individual time entries as billable, non-billable, or write-down
+  candidates under ABA Rule 1.5 reasonableness factors.
+- Drafting or reviewing billing narratives for specificity and professional
+  ethics compliance.
+- Designing or auditing IOLTA / trust account procedures, including three-way
+  monthly reconciliation.
+- Structuring a fee arrangement (hourly, flat, contingency, hybrid) or advising
+  on retainer replenishment thresholds.
+- Evaluating expense pass-through eligibility and markup ethics.
+- Applying jurisdictional fee-rule compliance for US state bars, EU bar
+  associations, or OAB Brazil.
+- Auditing a billing system for PII exposure risk or cross-border data-transfer
+  compliance under LGPD Art. 11 or GDPR Art. 9.
+
+Do not apply when the task is general accounts-receivable management outside a
+legal context — use `domains/finance-accounting/skills/bookkeeper-controller`
+for that.
+
+## PII Handling
+
+Legal billing data is inherently PII-dense and may carry legal professional
+privilege. The following controls are mandatory.
+
+**Data categories and classification:**
+
+| Category | Classification | Legal basis required |
+|---|---|---|
+| Client name, address, matter description | Personal data | LGPD Art. 7 / contract |
+| Adversary identity, case strategy, work product | Confidential + privileged | Legal privilege + LGPD Art. 7 |
+| Settlement amounts, financial terms | Confidential personal data | LGPD Art. 7 / contract |
+| Privileged communications (email, memo, call notes) | Legal privilege + personal data | Legal privilege; restrict access strictly |
+| Time entry narratives referencing third parties | Personal data (third party) | LGPD Art. 7 / legitimate interest |
+| Trust account balances and transaction records | Financial personal data | LGPD Art. 7 / legal obligation |
+
+**Mandatory controls:**
+
+- Never transmit client matter data over unencrypted channels (plain email,
+  HTTP, unencrypted file share). Use end-to-end encrypted legal portals or
+  TLS-in-transit with at-rest encryption.
+- Retention schedules must be matter-type-specific: active matters — retain
+  for the duration plus the applicable limitation period (varies by
+  jurisdiction; minimum seven years in most US states; OAB Brazil resolves
+  to five years post-matter-close); trust transaction records — retain for
+  the full limitation period applicable to bar disciplinary proceedings.
+- LGPD Art. 11 sensitive-category analysis: health information appearing in
+  personal-injury or workers'-compensation billing narratives, racial or
+  ethnic origin in discrimination matters, and religious affiliation in
+  estate-planning context are sensitive personal data. Processing requires
+  explicit legal basis beyond the general Art. 7 list; consent or legal-
+  obligation bases are typical. Document the basis in the data-processing
+  registry.
+- Cross-border transfer of client matter data (e.g., cloud billing platform
+  hosted outside Brazil) requires a valid transfer mechanism under LGPD Art.
+  33: adequacy decision, standard contractual clauses, or explicit client
+  consent. Verify transfer mechanism at platform onboarding, not after.
+- Access control: billing personnel access must be scoped to matters they
+  administer. Role-based access with audit logging. No bulk export without
+  attorney approval and logged justification.
+- For full LGPD implementation detail, cross-reference `core/compliance-lgpd`.
+
+## Billable Classification
+
+**ABA Model Rule 1.5 reasonableness factors** (applied as a classification
+checklist before entry approval):
+
+1. Time and labour required; novelty and difficulty of the questions involved.
+2. Likelihood that acceptance of the engagement precludes other employment.
+3. Customary fee in the locality for similar legal services.
+4. Amount involved and results obtained.
+5. Time limitations imposed by the client or circumstances.
+6. Nature and length of the professional relationship with the client.
+7. Experience, reputation, and ability of the attorney performing the work.
+8. Whether the fee is fixed or contingent.
+
+**Non-billable taxonomy:**
+
+| Category | Examples | Disposition |
+|---|---|---|
+| Firm overhead | Rent, IT infrastructure, malpractice insurance | Firm absorbs; never passed to client |
+| Billing and collections admin | Preparing invoices, chasing payments | Non-billable unless fee agreement specifies |
+| General training | CLE attendance unrelated to a specific matter | Non-billable |
+| Duplicative work | Two attorneys attending a routine call with no division of labour | Write-down to single timekeeper |
+| Excessive research on settled law | Basic research a competent practitioner would not bill | Write-down to reasonable time |
+| Clerical tasks | Photocopying, filing, scheduling | Non-billable or billed at administrative rate if disclosed |
+
+**Rounding ethics:** Round to the nearest 0.1-hour increment (six-minute
+minimum). Rounding up consistently to the nearest 0.5 or 1.0 hour is an
+ethical violation under Rule 1.5 and subject to fee arbitration.
+
+**Block-billing restriction:** On any matter where client billing guidelines
+or a court fee application prohibit block billing, each discrete task must
+appear as a separate line entry with individual time. A single narrative
+combining multiple tasks is permissible only where the guidelines explicitly
+allow it and each constituent task is still described.
+
+## Time Entry Discipline
+
+**Contemporaneous capture requirement:** Time must be captured on the day
+work is performed. Entries reconstructed from memory carry elevated dispute
+risk and reduced ethical defensibility. The outer limit for reconstruction
+without labelling is seven calendar days; beyond that, entries must be marked
+estimated-reconstruction and reviewed by the responsible attorney before
+invoicing.
+
+**Narrative quality standard:** Each entry must answer three questions:
+(1) what action was taken; (2) on what subject-matter or document; (3) to
+what purpose or result. Entries that answer fewer than two of the three
+questions are rejected and returned for revision before billing review.
+
+**UTBMS task-code mapping (litigation matters):**
+
+| Phase | Code range | Examples |
+|---|---|---|
+| Case assessment / development | L100-L190 | L110 fact investigation, L120 analysis |
+| Pre-trial pleadings / motions | L200-L290 | L210 complaint, L230 motion to dismiss |
+| Discovery | L300-L390 | L310 written discovery, L330 depositions |
+| Trial preparation / trial | L400-L490 | L420 experts, L450 trial attendance |
+| Appeal | L500-L590 | L510 appellate briefs |
+
+Transactional, real estate, and estate-planning matters use the B-series
+and P-series UTBMS codes respectively. Confirm the applicable code set with
+the client billing guidelines at engagement inception.
+
+**Matter-aware coding:** Each entry must be associated with the correct matter
+number. Cross-matter time allocation (one activity spanning two matters) must
+be split at entry time with separate entries for each matter; never apportion
+retroactively via journal adjustment without attorney sign-off.
+
+## Trust / IOLTA Accounting
+
+**Segregation of client funds:** Client funds held in advance of earning, cost
+advances, settlement proceeds pending distribution, and escrow must be
+maintained in a dedicated trust account separate from the firm operating
+account. Commingling — depositing firm funds into the trust account or using
+client funds for firm expenses — is bar discipline misconduct in every
+jurisdiction.
+
+**Permitted trust-to-operating transfers:** Transfer of earned fees from trust
+to operating occurs only after the fee is earned and the client has been
+notified. Transfers in anticipation of earning fees are premature and
+constitute commingling.
+
+**Three-way monthly reconciliation requirement:**
+
+1. Bank statement ending balance.
+2. Sum of individual client-ledger balances (each client's sub-account).
+3. Trust journal or system balance.
+
+All three figures must agree. Any variance requires same-day investigation and
+written explanation before the month closes. Unresolved variances are reported
+to the supervising attorney immediately; they are not carried forward.
+
+**Per-jurisdiction trust rules:** IOLTA rules in the United States are
+state-specific: minimum-balance thresholds for separate vs. pooled accounts,
+interest remittance schedules, and reporting obligations vary. EU bar
+associations maintain client account rules under national professional-conduct
+codes. OAB Brazil (Estatuto da OAB, Lei 8.906/1994, Art. 22 and Código de
+Ética Art. 50) requires separate management of client advances. Verify the
+operative rules at engagement inception; do not assume one jurisdiction's
+rules apply to another.
+
+## Expense Pass-Through
+
+**Cost vs. charge distinction:** Pass-through expenses must represent actual
+third-party costs incurred on behalf of the client. The recoverable amount is
+the actual cost paid unless the fee agreement explicitly authorises a markup
+and specifies the markup rate.
+
+**Markup ethics:** Charging above actual cost for photocopying, courier
+services, or computer-assisted research beyond what the fee agreement
+authorises is subject to Rule 1.5 reasonableness analysis and, in some
+jurisdictions, bar discipline. Disclose any markup in the fee agreement.
+
+**Receipt retention:** Receipts or vendor invoices must be retained for all
+pass-through expenses above the firm's threshold (minimum: receipts for
+expenses above $25 USD-equivalent; recommended: all pass-throughs). Retention
+period: same as matter-close retention schedule.
+
+**Tax categorisation:** Distinguish between costs the firm advances as agent
+(no revenue recognition; balance-sheet asset) and costs billed as firm
+charges (revenue at billing). Mis-categorisation creates accounting and
+tax-reporting errors. Coordinate with the bookkeeper-controller skill for
+treatment within the firm's chart of accounts.
+
+## Retainer Lifecycle
+
+**Retainer type definitions:**
+
+| Type | Mechanism | Depletion handling |
+|---|---|---|
+| True (classic) retainer | Lump sum paid to secure availability; earned on receipt | Non-refundable absent breach; held in operating account |
+| Replenishing retainer | Client advance held in trust; replenished when balance falls below threshold | Replenishment notice sent at threshold; matter pauses if not replenished |
+| Evergreen retainer | Replenishing retainer with automatic replenishment triggered by invoice | Client authorises automatic debit; agreement must specify amount and timing |
+
+**Depletion tracking:** Replenishing and evergreen retainers require per-matter
+trust-ledger tracking with balance-alert rules set at the replenishment
+threshold. Invoices drawn against trust must simultaneously update the client
+ledger and the trust reconciliation.
+
+**Refund on termination:** On matter close or client-initiated termination, any
+unearned retainer balance held in trust must be returned to the client promptly.
+Failure to return unearned funds is commingling and a Rule 1.15 violation.
+
+## Jurisdictional Compliance
+
+Fee rules, billing guideline requirements, and trust account obligations are
+jurisdiction-specific. The following is a mapping of operative sources; verify
+current rules at engagement inception.
+
+| Jurisdiction | Operative rules |
+|---|---|
+| US (state bar) | State Rules of Professional Conduct (Model Rule 1.5 + 1.15 as baseline); IOLTA rules published by state bar foundation; court-specific local rules for fee applications |
+| EU / EEA | National bar association professional conduct codes; CCBE Code of Conduct for EU Lawyers (Arts. 3.3 and 3.4 on fees); GDPR Art. 9 for sensitive client data |
+| OAB Brazil | Estatuto da OAB (Lei 8.906/1994); Código de Ética e Disciplina da OAB; LGPD (Lei 13.709/2018) for client data processing |
+
+No rule in this skill supersedes the jurisdiction-specific operative rule. When
+rules conflict, apply the stricter obligation and document the conflict.
+
+## Anti-patterns
+
+| Anti-pattern | Failure mode | Correction |
+|---|---|---|
+| Block billing on prohibited matters | Client guidelines or court rules disallow; invoice reduced or rejected | Decompose to discrete task entries before submitting invoice |
+| Padded entries | Billing more time than actually spent; Rule 1.5 violation; bar discipline risk | Bill actual time only; reduce narrative-padded entries before approval |
+| Commingling client funds | Trust balance used for firm operations or firm funds deposited in trust; Rule 1.15 violation | Immediate reversal; written explanation to supervising attorney; report if required by jurisdiction |
+| Retroactive reconstruction beyond 7 days | Memory-based entries are inaccurate and dispute-prone; reduced credibility in fee arbitration | Label as estimated-reconstruction; attorney review gate before invoicing |
+| Non-billable time on invoice | Overhead, billing admin, or purely clerical tasks billed to client; Rule 1.5 reasonableness failure | Classify against non-billable taxonomy; write off before invoice generation |
+| Missing billing-guideline compliance check | Corporate or insurance client guidelines violated (minimum increments, prohibited codes, block billing); invoice rejected or reduced | Validate against client-specific guidelines as a mandatory pre-invoice gate |
+| Unencrypted PII transmission | Client matter data in plain email or unencrypted storage; LGPD / privilege breach | Enforce encrypted channels; audit transmission logs; apply PII controls above |
+| Oral contingency agreement | Unenforceable in most jurisdictions; fee recovery risk | Require signed fee agreement before matter proceeds; no verbal confirmation |
+
+## Cross-References
+
+- `core/compliance-lgpd` — LGPD legal bases, data-subject rights, breach
+  notification, and cross-border transfer mechanisms for client data
+  processing; this skill inherits and specialises those controls.
+- `domains/legal/skills/client-intake` — conflict-of-interest checks, engagement
+  letter requirements, and client identity verification; precedes billing
+  engagement.
+- `domains/finance-accounting/skills/bookkeeper-controller` — chart-of-accounts
+  treatment of retainer advances, cost pass-throughs, and revenue recognition;
+  coordinate for accounting entries that mirror trust-account transactions.
+
+## ADR Anchors
+
+- **ADR-058** — two-pass review gate; applies to all billing deliverables
+  (invoice review, trust reconciliation, fee agreement structure) before
+  client transmission or matter-file lodgement.

package/.claude/skills/domains/legal/task-chains.yaml

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+# Task chains — Legal Squad
+# Domain-specific workflows that extend the universal .claude/task-chains.yaml.
+#
+# ADR-009 §bundle-completeness: ≥2 task chain entries required.
+# Each chain id follows legal-<short-slug> (kebab-case).
+# NOT canonical-guarded — no sentinel required for edits.
+#
+# Inherits PII core paths per ADR-111 (PLAN-080 Phase 0a).
+
+task_chains:
+  - id: legal-client-intake-pii-flow
+    title: "New client intake — matter opening with PII + privilege controls"
+    whenToUse: |
+      Triggered when a new client engagement is being opened in the
+      matter management system. Covers: conflict check, client PII
+      collection and residency assessment, matter record creation (append-only),
+      attorney-client privilege classification, retention class assignment,
+      and trust account setup if retainer is collected. Out of scope: billing
+      system configuration for AFAs (use legal-afa-setup chain) and
+      litigation e-discovery workflows (use legal-litigation-hold chain).
+    steps:
+      - id: 1
+        owner: "Amir Nakashima (Matter Management Engineer)"
+        action: "Conflict check: run adverse party index against all open and closed matters. Return CLEAR/CONFLICT result only — do not expose underlying matter details to the intaking attorney (LEG-002)."
+      - id: 2
+        owner: "Ingrid Vasquez (Compliance Officer)"
+        action: "Client PII assessment: identify client's home jurisdiction. If EU or BR, confirm data residency and SCC/adequacy status for the firm's processing stack (LEG-004). Assign retention class to the new matter record."
+      - id: 3
+        owner: "Amir Nakashima"
+        action: "Matter record creation: initialize with append-only document store. Set privilege classification default (attorney-client privileged) for all documents added to this matter. Confirm no client data pre-populates from a prior matter without explicit cross-matter consent."
+      - id: 4
+        owner: "Tobias Mensah (Records Manager)"
+        action: "Retention schedule assignment: bind the matter to the correct retention class (client file vs. firm work product vs. billing records — each has a different post-closure retention period). Record the expected destruction date."
+      - id: 5
+        owner: "Elena Sorokina (Legal Operations Lead)"
+        action: "If retainer collected: initialize trust account ledger for this client. Confirm three-way reconciliation baseline (matter ledger + client ledger + bank) before any funds are received (LEG-009)."
+      - id: 6
+        owner: "Ingrid Vasquez"
+        action: "Privilege audit: confirm no matter documents or client-identifying data are accessible to staff outside the matter's access control group. Run a cross-client isolation check (LEG-002)."
+      - id: 7
+        owner: "Chloé Bernard (Legal AI Integration Specialist)"
+        action: "If any AI-assisted intake (document classification, conflict analysis, client risk scoring) is used: verify DPA is in place for the AI vendor, confirm client matter text is not sent to a non-DPA-covered endpoint (LEG-001)."
+      - id: 8
+        owner: "Staff Code Reviewer"
+        action: "Merge check: conflict check returns CLEAR/CONFLICT only, retention class assigned, privilege ACL configured, trust account baseline recorded if retainer, no AI ingestion of matter content without DPA."
+    verification: |
+      - Conflict check result is CLEAR/CONFLICT only; underlying matter details not exposed (LEG-002)
+      - Data residency confirmed for EU/BR clients; SCCs in place if required (LEG-004)
+      - Matter record append-only; privilege classification default set
+      - Retention schedule bound with expected destruction date (LEG-005)
+      - Trust account three-way reconciliation baseline recorded if retainer (LEG-009)
+      - AI intake tools verified against signed DPA (LEG-001)
+
+  - id: legal-ai-tool-onboarding
+    title: "Onboard a new AI legal tool (document review, research, drafting assistant)"
+    whenToUse: |
+      Any time a new AI-powered legal tool is being integrated — document
+      review platforms, contract analysis tools, legal research assistants,
+      brief drafting tools, or AI-powered due diligence platforms. Triggered
+      at vendor evaluation, before any client matter content is shared.
+      Out of scope: general productivity tools that do not ingest client
+      matter content (use core onboarding workflow) and e-discovery platforms
+      with their own privilege protocol (separate legal-litigation-hold chain).
+    steps:
+      - id: 1
+        owner: "Ingrid Vasquez (Compliance Officer)"
+        action: "DPA review: request and review vendor's DPA specifically for attorney-client privileged material. Confirm: zero-retention at rest, no training use of client content, GDPR/LGPD SCCs for cross-border flows (LEG-001). Block onboarding if DPA does not explicitly cover privileged content."
+      - id: 2
+        owner: "Chloé Bernard (Legal AI Integration Specialist)"
+        action: "Technical verification of retention claims: confirm logging of inputs is disabled for client matter documents, confirm no fine-tuning pipeline receives client content. Request vendor's SOC 2 Type II or equivalent. Verbal 'zero retention' without technical evidence is insufficient (LEG-001)."
+      - id: 3
+        owner: "Ingrid Vasquez"
+        action: "Privilege protocol design: define which document types may be sent to the tool (privilege-waived documents only vs. with-privilege documents under DPA). Produce a privilege scope document signed by a supervising attorney before any client documents are processed."
+      - id: 4
+        owner: "Tobias Mensah (Records Manager)"
+        action: "Records impact: confirm AI-tool output (summaries, classifications, suggested edits) is stored with appropriate retention class — same as source document or shorter. AI-generated output must not extend the retention period of the underlying client matter."
+      - id: 5
+        owner: "Chloé Bernard"
+        action: "Accuracy validation: run the tool on a set of synthetic (non-client) legal documents. Check citation accuracy for any research feature (LEG-012). Document the hallucination rate and set a minimum human-review requirement before any output reaches a client deliverable."
+      - id: 6
+        owner: "Principal QA Architect"
+        action: "Integration tests: send a synthetic privileged document through the tool; verify no logging in the vendor's audit trail; verify the output is flagged as AI-generated and requires attorney attestation before filing (LEG-012)."
+      - id: 7
+        owner: "Staff Code Reviewer"
+        action: "Merge VETO check: DPA covers privileged content, zero-retention verified technically, privilege scope document signed, records retention impact assessed, citation accuracy baseline documented."
+    verification: |
+      - DPA signed and explicitly covers attorney-client privileged material (LEG-001)
+      - Zero-retention claim verified technically (no input logging, no training use) (LEG-001)
+      - Privilege scope document signed by supervising attorney
+      - AI output retention class ≤ source document retention class (LEG-008)
+      - Citation accuracy baseline documented; human-review gate configured (LEG-012)
+
+  - id: legal-matter-closure-archival
+    title: "Matter closure — archival, retention enforcement, and destruction scheduling"
+    whenToUse: |
+      Triggered when a matter is being closed and moved from active to archived
+      status. Covers document archival, retention schedule confirmation,
+      billing finalization, trust account reconciliation on close,
+      and destruction scheduling. Also triggered when an archived matter
+      reaches its scheduled destruction date. Out of scope: matters subject
+      to a litigation hold (destruction suspended; use legal-litigation-hold
+      chain instead).
+    steps:
+      - id: 1
+        owner: "Amir Nakashima (Matter Management Engineer)"
+        action: "Matter status transition: advance to 'Closed' via the state machine. Confirm no litigation-hold flag is active — if any hold is active, abort closure and escalate to Tobias Mensah (LEG-007)."
+      - id: 2
+        owner: "Elena Sorokina (Legal Operations Lead)"
+        action: "Billing finalization: confirm all unbilled time entries are either billed or written off with an audit trail (LEG-011). Confirm no open trust account balance — disburse or return client funds before archival (LEG-009)."
+      - id: 3
+        owner: "Tobias Mensah (Records Manager)"
+        action: "Retention schedule review: confirm the matter's destruction date (per the retention class assigned at intake). If the matter has mixed document types (client file + firm work product + billing records), each retention class applies independently."
+      - id: 4
+        owner: "Tobias Mensah"
+        action: "Backup inclusion audit: confirm that the backup system retains this matter only until the scheduled destruction date (no indefinite-retention backup tier includes this matter). Flag if any backup policy would extend retention past the scheduled date (LEG-008)."
+      - id: 5
+        owner: "Ingrid Vasquez (Compliance Officer)"
+        action: "Privacy sign-off: confirm client PII in the matter (contacts, financial details, sensitive communications) is subject to the same destruction schedule. No PII retained in analytics pipelines or AI training sets past destruction date (ADR-111 / Phase 0a core paths)."
+      - id: 6
+        owner: "Tobias Mensah"
+        action: "If destruction date reached: execute destruction workflow. Produce destruction certificate (record IDs, timestamp, actor, method). Confirm backup purge triggered. Store certificate in the firm's destruction registry (LEG-006)."
+      - id: 7
+        owner: "Staff Code Reviewer"
+        action: "Merge check: litigation hold clear, billing finalized with audit trail, trust account zero-balanced, retention schedule confirmed, backup purge confirmed at destruction, destruction certificate produced."
+    verification: |
+      - No litigation hold active at time of closure (LEG-007)
+      - All time entries billed or written off with audit trail (LEG-011)
+      - Trust account zero-balanced before archival (LEG-009)
+      - Destruction date scheduled per retention class (LEG-005)
+      - Backup retention confirmed to respect destruction date (LEG-008)
+      - Destruction certificate produced at scheduled destruction (LEG-006)