Strategies for Drafting Deposition Summaries

Deposition summary is an objective, accurate summary of the main points that are included in the deposition transcript. This summary has a key role to play throughout any litigation process. It will be quite time-consuming for the lawyers to handle the voluminous deposition transcripts, as it often includes hundreds of pages. Deposition summaries provide a brief overview of the deposition and help attorneys in their pretrial preparation. By outsourcing deposition summary preparation to reliable providers of medical review services, lawyers can better concentrate on the litigation process.

Throughout the litigation process, both the parties will rely on the deposition summary. Paralegals or expert summarizers at medical record review companies use certain strategies to summarize the deposition transcripts in a compact form.

Why Do Attorneys Need Deposition Summaries?

• Pretrial preparation
• Easy analysis of large volume information
• Speed up the trial process and verdict
• Highlight key points using charts or graphs

Deposition testimonies contribute greatly to bringing out the real facts from the witnesses. Well-documented deposition summaries are very useful during the course of a trial.

Different Types of Deposition Summaries

The different types of deposition summaries include page-line summaries, page-by-page summary, topic-by-topic summary, chronological summary, or narrative summary.

• • Page-line summaries are mainly formatted to include columns for page-line, exhibit and summary of testimony. With this summary type, often one page of summary will be prepared for every five or more pages of testimony.

• • Similar to the page-line summary, page summary is where the necessary points in a few pages are shortened and presented in two columns.

• • Topical summaries are summaries prepared based on predefined topics. This summary type is helpful in fact-oriented cases like workers’ compensation and has 3 columns – topic, pages, summary.

• • With chronological summary, the summary is abridged and arranged in chronological order. This option is ideal, especially in personal injury and criminal lawsuits.

• • In the narrative summary type, the summarized facts are presented in a narrative format and arranged as per the verbatim transcript.

Based on the requirement and the lawsuit they are dealing with, attorneys can determine the type of summary needed.

Deposition Summary Preparation Strategies

Here are some strategies to effectively prepare a deposition summary:

• • Thorough review: Start by thoroughly reviewing the deposition transcript. Familiarize yourself with the questions asked, responses given, and any exhibits or documents referenced. This helps to determine the nature of the case and the validity of the allegations. Focusing on the allegations will help the summarizer assimilate the supporting statements.

• • Identify key points: Highlight or mark key points, including important testimony, admissions, and contradictions. Focus on information that supports your case or undermines the opposing party’s position. Summarizers must make sure to avoid any unrelated information from the summary, which helps readers understand things in a timely and accurate manner. Also, include the breaks taken by the witness between specific statements, making it easy to locate the relevant summary parts.

• • Organize information and summarize: Structure your summary in a clear and logical manner. Group related testimony together and organize it chronologically or thematically for easy reference. Reduce lengthy responses into concise summaries while preserving the context and meaning. Use direct quotes carefully, opting instead to paraphrase when possible.

• • Highlight critical issues: Emphasize critical issues or topics discussed during the deposition. This helps prioritize information and ensures that key points are not overlooked. Also refer relevant exhibits or documents mentioned during the deposition. Summarize their contents and significance, and consider attaching copies for easy reference.

• • Presentation format matters: The way the summary is presented really matters. Plan the integral parts of the deposition and choose the presentation style and the summary type. A clear presentation format using columns will make the document easily graspable for the readers. It is best to provide the summary in two columns: a wide column on the right (testimony’s summary including the date, case, and witness name) and narrow column on the left (page numbers).

• • Maintain neutrality: Present the deposition summary objectively, avoiding any bias or subjective interpretation. Stick to the facts and let the testimony speak for itself. Also, proofread the summary carefully for accuracy, clarity, and completeness. Ensure that it accurately reflects the deposition testimony and is free of errors or omissions.

Who Prepares Accurate Summaries?

Some law firms may engage a third-party service provider to create deposition summaries. Preparing an effective summary requires attention to detail, legal knowledge, and the ability to effectively communicate complex information in a clear and understandable manner. At MOS, a leading medical record review company in the U.S., deposition summaries are typically prepared by skilled paralegals, legal assistants, and litigation support specialists. The time needed to complete the summarization depends on major factors such – as whether the witness is a layman or a professional, the size of the transcript, and the complexity of the case.

Expert providers of medical review services focus on creating excellent quality deposition summaries, taking care to reduce the lengthy testimony to relevant facts. All dates, names, figures, exhibits, and significant events will be clearly recorded. The summary will be neatly organized for easy perusal and understanding, and all unnecessary information will be weeded out.