Deposition Summary Steps

Depositions are vital in civil litigation and are one of the most important tools in the process of discovery. It is a must that lawyers and paralegals know how to summarize a deposition properly.

A deposition summary example will show you the basic steps to summarize a deposition.

The idea of a deposition summary is to give a summary of the person’s testimony in a concise and accurate manner. The summary needs to cover the relevant points of the deposition and is done for several reasons:

• Describe the deposition contents for the insurance adjuster
• Refresh the memory of the witness before the trial
• Prepare depositions of the same case
• Help attorneys who were not present at the deposition
• Allow attorneys to better get ready motions and evidence
• Support preparation for trial
• Summarize jurors’ testimony for the trial

The deposition summary preparation process has these steps:

• Reading: Going through the deposition transcript and focusing on key points and questions that are asked by lawyers, and the responses of the witness.
• Annotating: Highlighting key areas that should be included in the summary.
• Summarizing: Organizing vital points in a chart format, such as columns for testimony, topic, and page/line.

Before you do a deposition summary, it is critical to do background work. You need to go through all of the pleadings. This will assist you in drafting the summary with clarity and focus. Read everything carefully and know whether the complaint is of the witness or plaintiff. Focus on supporting facts and allegations while going through the pleadings.

Next, prioritize information. First, make sure there is no unrelated information in the summary. Second, summarize the key points so that it assists readers to understand things faster. Generally, you should summarize five pages of testimony into one page.

The next step is to include only essential details of the testimony. Leave out information that is of little value but include every vital detail that will help the lawyer. This can even include the breaks the witness takes to let readers know they took a break between certain statements.

Last, work on your presentation. You need to present it in a way that catches the eye because the presentation makes a big difference in the mind of the reader. For example, try to give the summary in a two-column format, with a wide column on the right and a narrow one on the left.