How to Prepare a Good Deposition Summary – Major Considerations

by | Last updated on Sep 8, 2023 | Published on Feb 19, 2021 | Deposition Summary

Deposition summary preparation is an important step in the development of a medical negligence or personal injury case. The deposition is a vital aspect for discovery because it reveals several important facts relevant to the case. Preparing the summary of a witness’ deposition is not an easy task; moreover, it demands extensive experience in the litigation field and good English writing skills. In addition, you need to understand the case and its related issues very well. To be useful during the course of a trial, deposition summaries must be well-documented and neatly formatted. A company providing medical review services can prepare accurate deposition summaries for attorneys.

What are the important considerations when preparing a useful summary of a witness’ deposition testimony?

  • The summary must be able to clearly communicate the key points covered in the full deposition transcript.
  • The summary can be prepared in a narrative format or written like an outline.
  • Apart from the written summary, key points in the deposition can be represented using graphs or charts.
  • Review the petition or complaint before starting with the summary. This is important to gain insight regarding the key facts that may be discussed during the testimony.
  • Read the entire transcript before summarizing it. Only this will help understand all the hidden details that may be important to the case. Moreover, a detailed reading will provide a clear sense of the general theme and tone of the deposition.
  • Include the essential details in the summary by focusing on the key facts that could prove useful during trial. Taking the time and effort to prioritize information will help avoid unnecessary or unrelated details from creeping into the summary. Experts point out that in a good deposition summary, information contained in five pages of witness testimony should be contained in a single page of the summary.
  • It is best to include information that may be beneficial as well as that which is detrimental to your case in the summary. Include all that the jury may be told if the case goes to trial. Negative testimony may be as significant as positive testimony because the attorney will be prepared to handle negative aspects in the courtroom in case of a trial.
  • For a well-structured summary, you can keep the line and page numbers in the left column and the summary in the right column, including the case, date, and name of the witness. Consider adding a table of index of contents if necessary.

Deposition summary software is available now that can be used to ease the process of summarizing the deposition transcript. Some law firms use such software and store the digital transcript in the cloud. The members of the legal team can access the transcript when they need it. Color-coded identifiers can be used to highlight any part they want, and they can annotate the text and share notes among others. Advanced software is also provided with an internal search feature that enables the legal team members to search and find the desired phrases or words in the lengthy deposition transcript.

Providers of medical review services focus on creating excellent quality deposition summaries, taking care to reduce the lengthy testimony to relevant facts. All dates, names, figures, exhibits, and significant events will be clearly recorded. The summary will be neatly organized for easy perusal and understanding, and all unnecessary information will be weeded out. Professionally prepared summaries help attorneys analyze important issues, gather facts and prepare the case well.

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