A deposition summary is one of the most important documents for court trial preparation. This concise manuscript enables attorneys to quickly identify the core of the deposition testimony and pinpoint valuable points without needing to review extensive data independently.
Lawyers will either create their own deposition summary or more likely assign the work to a litigation paralegal, while others outsource the work to a company specializing in deposition summaries.
You’ve also come to the right place if you need deposition summaries done for you.
Why You Need a Deposition Summary
Court procedures can be complex, and law firms rely on deposition transcription services to accurately capture the content of what was said. However, these transcripts can be lengthy, particularly if the deposition is long. This is why deposition summaries exist – to help lighten the load for lawyers. A deposition often yields much information unrelated to the legal process, so access to a summary is crucial. The deposition summary eliminates repetitive material, making it easy to review.
Here are the top reasons you need a deposition summary.
Aids in court proceedings
A deposition summary assists lawyers throughout the litigation process: arbitration, mediation, pretrial motions, or trial. Furthermore, it helps attorneys assemble and organize their evidence properly, facilitates motion preparation, and identifies crucial statements from specific witnesses. For covering specific legal proceedings such as trials, a trial transcription service can be used to document the event and be used, along with a deposition summary, for further court preparations.
Access to a summarized transcript can help legal teams determine other witnesses or participants that must be included in future depositions.
Since trials usually happen months or even years after the event, a witness may also refer to the deposition summary to refresh their memory before appearing in court, so they don’t accidentally misspeak.
Specifically, varying legal cases can benefit from deposition summaries. Below are some scenarios.
| Case Type | Scenario | Use of Deposition Summary |
| Personal Injury – Pretrial Settlement | The plaintiff sues for car accident injuries. | Attorneys can use the summary depositions of witnesses and experts to identify a strategy prior to a pretrial settlement. |
| Medical Malpractice – Trial Preparation | The doctor sued for alleged surgical malpractice. | The defense can use deposition summaries to prepare for cross-examinations and highlight key testimony. |
| Employment Dispute – Summary Judgment | The employee argues for wrongful termination. | Employers can include deposition summaries in motion for summary judgment to argue no trial is needed. |
| Commercial Litigation – Multi-Party | Multiple businesses in breach of contract lawsuit. | Deposition summaries help coordinate strategies and identify relevant testimony among numerous parties. |
| Criminal Defense – Impeachment | Witness gives conflicting trial and deposition statements. | The defense quickly identifies inconsistencies in witness summaries to impeach their credibility in court. |
Aside from deposition transcripts, lawyers can opt for legal transcription companies that can certify transcripts. These documents can be used in case preparation or even as evidence in legal proceedings.
Saves time
During a deposition, a lawyer can ask dozens of questions. However, depending on the attorney’s interrogation techniques, some could be irrelevant or redundant.
A deposition transcript typically consists of hundreds of pages documenting detailed conversations. Valid information will be scattered throughout, and a summarized transcript can help lawyers significantly reduce the time it takes to locate it.
A quick reference to essential information on a case helps legal teams employ effective trial strategies, thereby increasing their chances of success in their lawsuits.
Helps absent parties
It’s not just legal firms that need deposition summaries. People involved in a case who could not be present at the deposition (e.g., deponents, plaintiffs, insurers, or adjusters) would benefit from a brief transcript summary they could review.
5 Main Types of Deposition Summaries Explained
There are five primary types of deposition summaries: page-line summaries, page summaries, topical summaries, chronological summaries, and narrative summaries.
- Page-line summaries typically have columns for page-line, exhibit, and summary of the testimony. Generally, you can expect a one-page-line summary for every five or more pages of testimony.
- A page summary is a tool that condenses and organizes key points from multiple pages into two columns.
- A topical summary comprises three sections: topic, pages, and summary. It is typically used in cases such as workers’ compensation, where facts are the main focus.
- Chronological summaries allow for abridgment and chronological arrangement of material, often used in personal injury and criminal lawsuits.
- The narrative summary deposition organizes and presents the facts from a verbatim transcript in a narrative style.
The attorneys can decide which type of summary is necessary based on the requirement and the lawsuit they are dealing with.
Step-by-Step Guide to Writing a Deposition Summary
When we write our deposition summaries, we find it best to consider these simple steps:
Read the entire deposition
Writing a good deposition summary involves understanding the basis of the complaint. That entails going through the entire document (i.e., a verbatim transcript of witness statements) to understand the purpose and context of the deposition.
For example, identifying what the attorney is getting at, and seeing if the witness testimony refuses to cooperate, delivers contradictory statements, etc., will help obtain a frame of reference to determine the nature of the case and assess the validity of the accusations.
Highlight important statements
We pinpoint the information to prioritize and eliminate irrelevant details in the summary. It should contain the focus of the deposition. Once identified, understanding these key statements is crucial for summarizing them effectively.
Determine key parts
Deciding how much detail to include in the summary can be time-consuming and effort-intensive. We must find a balance between brevity and intricacy, which can be tricky.
The key here is to focus on the facts that could be useful at trial.
Here’s a good rule of thumb we use here at Ditto Transcripts: Deposition summaries should be able to communicate ten pages’ worth of testimony in a single page.
What Makes a Good Deposition Summary?
Once we’ve drafted a deposition summary, we’ll double-check to see if it has the following features to see if it’s up to our standards:
- It contains essential details, such as the witness’s name, case name, date, and a table of contents or index at the end of the document.
- It presents the deponent’s statement in a factual and concise format. There is no repetitive content, and significant testimonies and possible causes for witness impeachment are highlighted.
- All pertinent details that the lawyer may need during the trial are included, such as critical statements from the witness, the page and line number of the statement, and details of exhibits used in the case.
- The information in the summary corresponds to the lines and pages of the original transcript to allow for easy referencing to the verbatim text.
- Information is supplemented with graphs or charts for better presentation, if applicable.
- It is well-formatted. Typically, a deposition summary will have two columns, with the left one making up a fourth of the page’s width. This formatting allows the line and page numbers to be included in the margin space on the left, lending space for the date, case identifiers, witness names, and the summary to be placed in the right column.
How Long Does a Deposition Summary Take to Complete?
If you know what you’re doing, it takes about one hour to summarize a deposition transcript 25 pages long.
That said, the amount it takes to complete a deposition summary will differ based on the factors outlined below:
Witness type
Is the witness a layman or an expert? If it’s the former, the deposition will be easy to brief. However, depositions involving doctors or engineers can get complicated and take longer to understand and summarize.
Deposition size
A deposition can sometimes be lengthy and typically contains upwards of 200 pages. Naturally, the longer it is, the more time it will take to summarize.
Case difficulty
Cases involving multiple defendants, multiple injuries, or unreliable witnesses can lead to more complex depositions, which in turn increase the turnaround time for a summarized transcript.
Get Professional Deposition Summaries from Ditto Transcripts
Even if you know how to write a deposition summary, the time and effort involved in completing the task may make you reconsider other options, like hiring a deposition summary company. If you are, I recommend hiring our company to do the hard work for you.
Ditto Transcripts offers deposition summary services for clients in our home state of Colorado and states coast to coast. We offer 99% guaranteed human transcription accuracy. We understand that every state and county has specific formatting requirements, so our team will work with you to meet your needs.
We can summarize approximately 20 pages per hour, with a maximum of 25 pages if the case is less complicated. Complicated cases will take longer, but we will average about 20 pages per hour.
Our affordable and cost-effective deposition summary services prices are $3.50 per page. However, if we also complete the deposition transcript, we can offer a reduced rate of $2.25 per page.
Ditto’s legal transcription prices are transparent. This way, you’ll know exactly what you’re paying before your deposition summary is produced. No surprise fees.
Your completed deposition transcripts can be sent to us via email or our secure online portal. If you’d like, you can pick up your finished document(s) personally at our office – or we’ll send it to you by email. You may also arrange for us to send you a hard copy.
Ditto Transcripts takes pleasure in its work, which includes quality control and individual account managers for each client. If you hire us, you can be confident knowing you’ll quickly get accurate deposition summaries for your upcoming hearings.
Ditto Transcripts is a transcription services company based in Denver, Colorado. We provide fast, accurate, verbatim transcription and nonverbatim transcription. You tell us what you need and we’ll do it. For individuals, government agencies, and companies of all sizes. Call (720) 287-3710 today for a free quote.