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Drafting a Precise Deposition Summary: 7 Facts You Must Know

by | Apr 8, 2024 | Personal Injury


What is a deposition summary? Deposition summary is the condensed and laconic version of the voluminous deposition transcript. It plays an important role throughout the litigation process. Attorneys cannot go through the multitudinous pages to detect the valuable points that help them succeed in their lawsuits. Paralegals, lawyers, or expert summarizers will summarize depositions and present them in a compact form. This blog analyzes the necessity and the procedures of preparing a well-built deposition abstract in detail.

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What Is a Deposition?

A deposition is a part of the litigation, which is in the recorded format of the statements of the witness about what he/she knows of the particular case. What does deposition look like? It is in the form of questions and answers recorded when the witness is under oath. Usually, it is taken outside the courtroom for new discoveries pertaining to the litigation. Attorneys will interrogate the witness to understand the facts behind the case as well as the stand taken by the witness in it.

Usually, a deposition testimony consists of hundreds of pages in the form of detailed conversations. Valid information will be hidden and scattered among the bulky deposition transcripts. As it plays an integral part in the pre-trial and trial process in the court, the lawyers have to refer to it and decide the next step to be taken to win their litigations. When litigation needs many witnesses to be deposed, the process becomes more complicated.

Why Do You Require a Deposition Summary?

The purpose of a deposition is to help the lawyers in their complicated court procedures. Deposition contains a lot of information unrelated to the legal process. Therefore, the transcript should be made crisp for easy perusal by eliminating redundant materials. The main reasons why deposition should be condensed are as follows:

The-reasons-why-you-require-a- deposition-summary

  • Vital throughout the process: The succinct deposition summary succors the attorneys to pursue their litigation successfully during mediation, arbitration, pre-trial, or trial.
  • Time-saving: When the lawyers have many witnesses in their case, reviewing multiple pages in the different depositions takes the toll. In such situations, briefing the enormous documents will help the litigators to refer for the vital points in a short time.
  • Helps the absent parties involved: It helps the people involved in the litigation like insurers or adjusters, deponents or plaintiffs, and even attorneys if they are absent during the testimony.
  • Helpful in pre-trial preparations: It helps in preparing discovery demands, responses, and interrogatories. It guides the lawyer to decide the other witnesses to be included for deposition. It also refreshes the witness’s memory of the event before the trial.
  • Vital in the court proceedings: It enables the attorneys in preparing for the motions and assembling the evidence during trials. It helps to identify the inevitable testimonies of certain witnesses or to impeach the unreliable witnesses from the litigation.

How to draft a deposition summary accurately?

Writing a deposition summary demands the following procedures.

  1. Skim the transcript: Read the entire deposition to understand the context and purpose of the deposition. Perceiving what the attorney aims at and how the witness responds or refuses to answer, stutter or give contradictory statements, etc., will help to discern the nature of the case and the validity of the allegations. Focusing on the allegations will facilitate the summarizer to assimilate the supporting statements.
  2. Annotate the key statements: Identify the relevant points to be included in the depo summary and annotate them for easy understanding while drafting the deposition summary. This will help elucidate the justifiable statements favoring the lawsuit.
  3. Decide the integral parts of the deposition: From the highlighted key points, the summarizer should decide how to form the summary of the deposition. Planning the integral parts, the style of presentation, and the type of the summary will make the document easily graspable for the readers.

The deposition summary process requires the knowledge to collate, combine and draft the synopsis in precision, and not to reproduce it in its entirety. Digesting a deposition is a lengthy process that needs utmost care and scrutiny since it plays an inevitable role in winning the litigation.

What decides the time taken to brief a deposition?

Generally, in an hour more than 25 pages of the deposition transcript can be summarized. However, depending upon various factors, the time taken to compress the deposition differs from a few hours to many days. They are

  1. The position of the witness: If the witness is a layman, the transcript will be easy to brief, whereas the depositions of expert witnesses like doctors or biomechanical analysts are complex and will take more time to understand and create terse summaries.
  2.  Size of the transcript: Generally, the size of the transcript varies from 50 to around 200. More pages take more time to brief it.
  3. The complexity of the case: Cases with multiple injuries, more defendants, longer treatment, and unreliable witnesses make the depositions complex to understand and make discoveries that help the litigation.

Why Do You Need Deposition Summary Services?

Even if you know how to summarize depositions, the intricacies involved in summarizing depositions would undoubtedly make you consider the necessity for deposition summary companies. The following factors stress the need for outsourcing to the deposition summary services.

  • Time-efficient: Lawyers will be time constraint with their tight schedule handling multiple cases at a time. Summarizing a deposition is a time-consuming process, and in-house summarizing also will affect the other processes in the litigation. If the work is outsourced to expert deposition summaries services, experts proficient in English and experienced in legal and medical fields summarize the transcripts in a jiffy. Some even provide expedited services.
  • Cost-efficient: Most of the paralegal staff or lawyers in law firms are paid per hour for summarizing. It is important but expensive work and would cost an arm and a leg for the clients. If outsourced, effective deposition summaries will be ready at a very low cost. Pocket-friendly transcript services will be a boon to clients who are already under financial burden.
  • Cumbersome work made a piece of cake: Reputed summary services have well-trained paralegals or experts to digest the valuable points from complex depositions. They are more experienced in legal matters and understand the nature of the case and strain the valid points that would help the litigation process. Professionally created deposition documents are more reliable while picking out the favorable factors for the clients.

Deposition summary is part of the services provided by many medical record summary services, which lawyers can avail of to relieve their burden and concentrate on the litigation process.

What Should the Deposition Summarizer Keep in Mind?

Before attempting to write the summary of the deposition, the paralegal or the summarizer should keep these points in mind.

  • Understand the context and circumstances of the deposition to decide what should be included or excluded.
  • Include the name of the witness, case number, date of the deposition, location, and the details of the appearing counsel
  • Encompass all the pertinent points the attorney needs
  • Try not to amend the context of the deposition
  • The summary should comply with the verbatim transcript
  • Present the deposition summary from an objective point of view. Never include the summarizer’s subjective comments or viewpoints.
  • Be accurate in recording the valid points
  • Avoid repeating the points referred to in multiple places
  • Refrain from editorializing while briefing the transcript
  • Mention the breaks taken in between the process for the attorneys to identify the relevant parts of the deposition

What Are the Types of Deposition Summaries?

To draft a crispy and effective deposition summary, you should know the various types of depositions. Here we are going to see the different deposition summary examples.

1. Page-line Summary:

Page-line summaries are prepared by straining the vital information page by page. When compared to the other methods, this is a time-consuming one. A carefully drafted page line summary collects important statements of the witness by referring to the beginning and end page and line. This method is more convenient in commercial and financial transaction cases. For example, if a statement begins on page 4 line 20, and ends on page 7 line 8, it would be mentioned as 4:20-7:08. It consists of two columns with page and line in one and a condensed summary in the other. Minimum 5 pages will be compressed into a single page. Go through the page line deposition summary sample to understand it better.


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LDDS001 – Deposition Summary – Page Line


​2. Page Summary:

Page summary is also somewhat similar to the page-line summary, where the necessary points in a few pages are abridged together and presented in two columns. The laconic deposition summary is included in one, and the starting and ending page numbers are mentioned in the other. For example, pages will be referred like 5-10 or 55-59. the following sample of deposition summary will be of great use for you.


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LDDS004 – Deposition Summary – Pagewise


3. Topic-by-topic Summary:

As per the title, the summary of deposition is prepared under specific topics. After skimming the deposition in its entirety, topics will be predefined. Related points are gathered and assembled under the relevant topics. This type of summary will be helpful in fact-oriented cases like worker’s comp. This will have 3 columns – topic, pages, summary. For example, the topics will be similar to -witness’s address, education, present job, previous job, prior accidents, subject accident, subsequent accidents, injuries, etc. The given sample deposition summary will definitely guide you to draft one.


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LDDS005 – Deposition Summary – Topic by Topic


4. Chronological Summary:

The transcript summary is abridged and arranged in chronological order. The chronological sequence of facts is pivotal, especially in personal injury and criminal lawsuits. Lawyers prefer to have all the depositions taken, incorporated, and organized sequentially. Enrich yourself by going through this chronological deposition summary example.


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LDDS002 – Deposition Summary – Chronology Summary


5. Narrative Summary:

The transcript is perused, and the important facts from the witness’s testimony are collated. Then the summarized facts are presented in a narrative format and arranged as per the verbatim transcript. Most of the insurance providers prefer this kind of deposition digest. Sometimes more than ten pages will be condensed into a single page.

From the different types of sample deposition transcript summaries available, the attorneys can determine the type that suits their lawsuits. The deposition summary format given below will blow your mind.


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LDDS003 – Deposition Summary – Narrative Summary


Final Thoughts

Deposition transcript summary is an inevitable part of the litigation services, which minimizes the burden of the litigators in reading the massive number of deposition pages. Compressing the mammoth depositions to gnomic and crispy summaries need language proficiency and expertise in legal matters. Deposition summary services work in compliance with the law firms in giving terse legal deposition summaries in expedite budget-friendly services.

A foundational step in understanding how to do a deposition summary involves acquainting oneself with a well-structured deposition summary template, which can serve as a roadmap to identifying and extracting the most pertinent information. Leveraging a sophisticated deposition summary software or deposition review software can significantly streamline this process.

Make use of the given examples of deposition summaries to boost your work.

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