How to write a Deposition Summary?

Depositions are notoriously long and meandering. Depending on the witness and their skill set, a deposition can contain dozens or hundreds of pages that have little relevance to the actual case.

But it is a matter of great professional importance that all relevant deposition testimony must be presented to the court. 

For this reason it is vital that the deposition summary be carefully crafted to include all relevant information, in a clear and concise format that makes sense for the case and the structure of the interview.

If you are unsure where to start, here are the most important steps for writing a great summary deposition that will help the legal team and the judge to get the most important information from the deposition summary without reading hundred of pages.

Reading Well: The Key to Summarizing Well

In order to write a useful summary of the deposition, you must first achieve an understanding of the material within the deposition.

Many writers use highlighters in different colors at this stage, helping testimony about different aspects of the case to stand out from the surrounding material that may be less relevant. 

At this stage you will have to be careful about cherry picking; leaving out information that is less than flattering to your client can backfire badly if the judge notices that it was omitted from the summary.

The Outline: Creating Coherence

Depositions may include lots of rambling, drifting from one topic to another only to return to the original topic later on. 

Crafting an outline helps you to rearrange the testimony material into a format which make sense and easy to follow. 

You may include quotes directly from the testimony when they are relevant, but sometimes it will make the most sense to condense large blocks of testimony into a few sentences.

As you outline the material, make sure to include page and line numbers alongside the material in your outline so that you won’t lose track of where in the deposition document it was originally found.

The Deposition Summary: Choose Your Format And Craft Your Document

Depending on the type of case and the nature of the testimony, many types of deposition summary may be appropriate. 

If the judge is likely to use your deposition summary as a guide and also read the deposition itself, you can ease their task considerably by creating a page-line summary, with numbers that shows the source of each quote. 

For summaries of narrative depositions a chronological summary may make the most sense. While the deposition testimony may jump forward and backward in time, your summary can rearrange the relevant information into chronological order–making the narrative much easier to follow.

On the other hand, for a more technical deposition, a topical summary may be the best route to choose.

All of these summaries should be easy to craft once you have a solid, accurate outline to work from. 

Writing an accurate, useful deposition summary is an important part of a well prepared case. Don’t skimp on this step; you will be rewarded when the judge can see your respect for the courtroom and the integrity with which you have handled the evidence.