Having a deposition summary is not sufficient. It needs to be good, it needs to be effective, clear, concise and most importantly, it needs to highlight the right material.
To help you accomplish this we are going to go over some key tips to help you make your deposition summary the best it can be.
Before you start it should be mentioned that whoever is assigned the task of writing the deposition summary should be detail-orientated, capable and comprehensive. Usually the best options for such a task would be a writer specializing in this skill, an attorney or a paralegal.
What You Should Do:
- Review the entire testimony and take notes. Then select the key points that are essential to your case.
- Consider the context of events so you know what to include or leave out but also so that you can keep the information in the correct context. Facts can change meaning depending on the circumstances surrounding them.
- At the beginning of the document write the witness name, case info, relevant date and a table of contents for easy reference.
- State matter of fact details without any perspective opinions or artistic license. Everything should state the information clearly and accurately without editorializing the content. Exact wording of questions and answers are usually useful to include.
- Read through your summary once complete and remove any repetitions of information or anything that seems irrelevant or inaccurate.
- Finally, format the entire document to make it easier to read and so the main points stand out to the reader.
A well put together deposition summary takes into account the entire succession of events along with the attorney questions and witness answers. An easy way to get the meat from the testimony is to read through the entire transcript and annotate the key points that can be transferred to the summary.
To make the summary simpler to read, we recommend a chart format where you organize the content by topic, page/line & testimony. Though every case is different and we recognize that the amount of key info may vary, a good estimation for deposition summaries is to have about 1 page of summarized content per 5 pages of witness testimony.
Once you have completed your deposition summary you should have something that is easy to use and clearly comprehensible at a moment’s glance. If it is not, then don’t worry, just keep working on it until it looks simple, clear and concise.