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How to Draft a Issue-Based Deposition Summary

Especially complex litigation, issue-based deposition summaries can be incredibly useful. This guide explains how to create issue-based deposition summaries.
Dodonai Staff
6 mins

In litigation, especially in cases with complicated issues such as a complex commercial dispute, drafting an issue-based deposition summary can be incredibly useful. Unlike the page-line summary method, which organizes information numerically by page, a topic-based summary groups testimony by key case issues. This approach not only enhances the organization of information but also streamlines the review process for legal teams.

Understanding Issue-Based Deposition Summaries

An issue-based deposition summary focuses on the main issues or topics discussed during the deposition, categorizing related testimonies together regardless of their order in the transcript. This method is particularly effective in fact-specific cases where understanding the nuances of each issue is crucial to the case's outcome.

Steps to Drafting a Issue-Based Summary

  1. Identify Key Issues: Begin by reviewing the case to identify its key issues or issues. These will serve as the main categories for organizing the deposition testimony.
  2. Review the Deposition Transcript: As you go through the transcript, extract relevant testimony and categorize it under the identified issues. This may require a comprehensive first read to ensure no critical information is missed.
  3. Organize Testimony by Issue: For each issue, summarize the relevant testimonies, including page and line references for precise location. This allows for quick access to the original transcript if needed for more context.

Example of a Issue-Based Summary Format for a Workplace Discrimination Case

Issue: Alleged Discrimination in Promotion Decisions, May 2020

  • 32:5 – 33:10: Witness details observing the selection process for the managerial position in May 2020, noting a lack of consideration for minority candidates.
  • 45:2 – 46:7: Testifies to overhearing a conversation between senior management expressing preferences for candidates that did not include minorities, specifically mentioning concerns about "fit" within the company culture.

Issue: Harassment Complaint Handling, June 2020

  • 67:15 – 68:22: Witness describes their experience reporting harassment to HR in June 2020 and the inadequate response that followed, including a lack of formal investigation.
  • 72:4 – 73:6: Provides names of other employees who reported similar experiences, suggesting a pattern of negligence in addressing harassment complaints.

Issue: Workplace Retaliation, July 2020

  • 85:3 – 86:9: After reporting discrimination, the witness recounts instances of retaliation, including being excluded from meetings and receiving unjust negative performance reviews.
  • 90:10 – 91:5: Mentions conversations with colleagues who faced similar retaliation after lodging their complaints, indicating a hostile work environment.

Tips for Drafting Issue-Based Summaries

  • Comprehensive Issue Identification: Start by thoroughly understanding the case to identify all relevant issues. This may involve discussions with the legal team to align on the case's core aspects.
  • Detailed Testimony Extraction: When reviewing the transcript, pay close attention to testimonies that directly address the identified issues. This approach ensures that your summary captures all relevant viewpoints and evidence.
  • Clear Organization: Use clear headers for each issue and subheaders for specific incidents or testimonies within those issues. This helps maintain an organized structure that's easy to navigate.
  • Highlight Key Evidence: Bold or italicize particularly impactful testimonies or phrases within each issue's summary. This visual differentiation can quickly draw attention to the most crucial evidence during review or discussions.


An issue-based deposition summary is a strategic tool for legal professionals, offering a structured and efficient way to navigate through complex testimonies. By focusing on the key issues of a case, attorneys can more easily access the information most relevant to their arguments and preparations. This method not only saves time but also ensures that critical insights and details are not overlooked, contributing to a more thorough and effective case strategy. To save even more time and ensure that all issues are addressed, use an AI deposition summary software like Dodonai's.

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