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Key Tips to Summarize Deposition Testimonies

tips to summarize deposition testimonies

A deposition summary is a reduced version of a long deposition transcript. Deposition testimony is the most crucial part of any litigation. Deposition testimony may be used at trial to impeach a witness on the stand and it will provide substantive evidence to support the case. Here, the attorney will ask the witness a series of questions about facts and events related to the lawsuit with the entire deposition recorded word-for-word by a court reporter. A deposition can also be videotaped. After the deposition, the court reporter prepares a written transcript of the deposition testimony and sends it to the attorneys. Often, depositions are lengthy and may last many hours and so, these transcripts should be summarized. Deposition summaries offer a concise overview of the deposition and helps in the pretrial preparation.

Professional companies provide reliable deposition summary services by carefully extracting the facts from the testimony and converting them into an easy-to-use format, making it easier for legal entities to review the key points.

Summarizing Testimonies

After carefully reading a full deposition transcript, an attorney or paralegal summarizes the transcript into a briefer document. A paralegal, attorney or a specialist writer performing the summarization process must be capable of recognizing the main points associated with the testimony and should have high-quality comprehension skills. They should be able to understand the legal points and pick out the main points inclusive of the supported/non-supported variation by the witness.

Two common ways of summarizing a deposition transcript are – Topical summary or Page-by-page summary. While a topical summary extracts a portion of the transcript that deals with one specific topic and summarizes that material, page by page summary checks each page and makes a summary of it till the last page.

When summarizing a transcript, it is crucial

  • To include all relevant materials that are helpful for the attorney
  • Make sure not to alter the context of the material
  • To convey the spirit of the question and the response of the witness within the summary
  • To avoid editorializing in the summary
  • To maintain a neutral attitude when reading the deposition and summarizing the material
  • To restate the information obtained from the response to the questions
  • Review the entire testimony, analyze, take notes, and then decide the integral points
  • Consider the context and circumstances to decide what needs to be included or avoided
  • Maintain accuracy and ensure that there is no repetitive or extra text
  • Note the break to help the attorney easily locate the relevant part in the summary
  • Provide the summary in a two-column format with page and line numbers and a summary
  • Include the name of the witness, case name, and date and a table of contents or index

Deposition Summary Process

The summarizing process typically includes three basic steps: reading, annotating and summarizing a deposition transcript.

A well-worked summary requires a thorough and thoughtful reading of the entire transcript as well as paying attention to the questions that attorneys ask and the response of witnesses. Annotating follows reading the transcript and here the paralegal or attorney makes notes throughout the transcript text and highlights all key points that should be included in the summary. If multiple team members are there, they may annotate the transcript and another legal professional may incorporate all the notes into the final summary. To summarize, key points in the summary will be organized in a chart format, which include columns such as “Page/Line,” “Topic” and “Testimony”. Summaries can be prepared in a narrative format or an outline format.

Though there is no fixed page limit for the summaries, a well-drafted deposition summary should contain no more than one page of summary for every five pages of testimony. Legal entities can consider the support of experienced medical review companies providing deposition summary and related services. Such companies provide the services of skilled medical and legal professionals along with other personnel with specialized backgrounds in law, technology, science and English.

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