Deposition summaries are incredibly important in the trial process. They help lawyers study depositions fast and see highlights of the witness depositions.
However, there’s no one particular way to write the deposition summary. There are three different formats that a depo summary can take. Here they are:
Formats of Deposition Summaries
Page/Line Summary
This depo summary format states the key points at different times during the deposition. It’s often presented in a table with two columns. The first column contains the time range, and the second column has the keypoint of that entire time. For instance:
13:20 – 14:30: He admits being present at the scene and seeing John hit Richard across the face.
This means, from page 13 line 20 to page 14 line 30, this is what was discussed. Page/line summaries take the most time to complete and are perfect when the attorney wants to get a detailed picture of how the testimony went.
Issue summary
This format of depo summaries focuses on issues that were discussed during the deposition. Unlike the page/line format, it doesn’t go chronologically. Instead, the summary picks the important topics and lists when they were talked about and what was said.
The topics and different sections of the summary are separated by headers and topics. Even though the summary discusses topics, it can take the format of the page/line summary. Another way to do an issue depo summary is to pick a topic, and summarize what each witness had to say. It’s perfect if the attorney wants to easily compare what the different witnesses said about the same topic.
Page summary
This is by far the easiest summary to prepare. It’s somewhat like the page/line summary, but a lot broader.
Example:
10 – 12: Agnes claims she was at the scene
12 – 15: She witnessed the crime
16 – 28: Timeline is established
The page summary is perfect if the litigator wants to see how the testimony progressed, or find a certain part of the deposition. It’s somewhat like a table of contents, allowing you to look up certain parts of the deposition.
Conclusion
Deposition summaries take a lot of time to complete. A paralegal typically has to go through hundreds of pages of deposition transcripts to prepare the summaries. For the average experienced paralegal, it takes about 10 hours to write a summary from a 200 page deposition transcript.
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