A deposition summary is one of the most important documents for court trial preparation. This concise manuscript helps attorneys get to the core of the deposition testimony and identify valuable points without having to read large volumes of data on their own.
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. For this reason, deposition summaries help lighten the load for lawyers. However, a deposition comes with much information unrelated to the legal process, so access to a summary is vital. The deposition summary eliminates repetitive material and allows for easy perusal.
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. Further, it helps attorneys assemble and organize their evidence properly, helps motion preparation, and identifies crucial statements from certain witnesses.
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.
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 lessen the time it takes to spot them.
A quick reference for essential information on a case helps legal teams employ effective trial strategies, increasing their chances of succeeding 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.
The Types Of Deposition Summaries
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.
- Page summary is a tool where key points from multiple pages are condensed and organized 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.
How We Write a Deposition Summary
When we write our deposition summaries, I 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 essential to be able to summarize them.
Determine key parts
Deciding how much detail to include in the summary can take time and effort. We have to find a balance between brevity and intricacy, and that 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 name, case name, date, and a table of contents or an 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 It Take To Summarize a Deposition?
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:
Is the witness a layman or an expert? If it’s the former, the deposition will be easy to brief. But depositions involving doctors or engineers can get complicated and take longer to understand and summarize.
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.
Cases with several defendants, multiple injuries, or unreliable witnesses make for more complex depositions, increasing the turnaround time of a summarized transcript.
Ditto Transcripts Can Help You Get Certified Deposition Summaries
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 understand that every state and county has specific formatting requirements, so our team will work with you to meet your needs.
We can summarize about 20 pages per hour, 25 at most if it’s a less complicated case. Complicated cases will take longer, but we will average about 20 pages per hour.
Our affordable and cost-effective deposition summary services prices are $4.00/page. However, if we also complete the deposition transcript, we can offer a reduced rate of $2.25/per page.
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. And if you’d like, you can pick up your finished document(s) personally at our office at 3801 E Florida Ave., Suite 500, Denver, Colorado – 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.
Don’t hesitate to contact us for a certified deposition summary transcript. Call us at (720) 287-3710 to get started.