Different Types of Deposition Summaries

December 6, 2022
Deposition Summaries

Deposition summaries are a tool used by attorneys to help them prepare for court. 

They are brief, written accounts of the most important information that was discussed during a deposition. Deposition summaries can be used in a variety of ways, from preparing for trial to avoiding trial altogether.

Sometimes it can be difficult to know which is the best depo summary that suits your needs. 

If you are unsure, here are some helpful tips:

1. Page-Line Summaries

These are the most basic type of deposition summaries and they simply list each page number and line number where the witness mentions certain topics or events. 

This type of summary is useful for quickly finding key information in a deposition transcript. However, it does not provide any context or analysis for each topic mentioned by the witness. 

2. Page Summaries

These summaries are similar to page-line summaries but they also include an exact quote from each line on which there is an important statement made by the witness. The quotes from each line are usually italicized so they stand out from other text in the deposition transcript. 

This format makes it easy for attorneys to find specific portions of testimony quickly and accurately when doing research for trial preparation or settlement negotiations. 

3. Topical Summaries

A topical summary is a summary that lists key points from the deposition. It may include headings, but it should not include extensive explanation or commentary.

4. Chronological Summaries

A chronological summary is organized in chronological order by date or time period. This type of summary is useful for identifying patterns or events over time, but it may not be as useful for finding specific information about a particular topic or issue.

5. Narrative Summaries

A narrative summary provides an overview of the witness’s testimony in a form that reads like a story rather than a list of facts and details (e.g., “On March 2nd, 2019, Ms. Smith told me about her experience at work”). 

It may be used when there are multiple witnesses who testify on similar topics or issues so that all of their testimony can be grouped together for easier comparison and analysis later on down the road if necessary.”

Final Thoughts

Depositions are an important part of the litigation process. They can be either written or oral, and they serve a number of purposes. If you need help, do not hesitate to contact our team of experts.

Author bio-

Sheila LaCivita is the owner of 4 Corners Depo. She got a paralegal degree with distinction from UCLA and has been helping lawyers with deposition summaries. She wants to share her knowledge and experience with others.

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