Deposition

How to Draft a Page-Line Deposition Summary

Deposition summaries are invaluable tools in legal proceedings, providing attorneys and legal teams with quick references to crucial testimonies. Here’s a guide on how to effectively draft a Page-Line Deposition Summary.
Dodonai Staff
5 mins

Deposition summaries are invaluable tools in legal proceedings, providing attorneys and legal teams with quick references to crucial testimonies. Among the various methods of summarizing depositions, the Page-Line Summary stands out for its precision and utility, albeit being the most time-intensive. Here’s a guide on how to effectively draft a Page-Line Deposition Summary.

Understanding Page-Line Deposition Summaries

The Page-Line Summary method involves detailing the deposition transcript by citing specific page and line numbers where key testimony is found. This approach allows legal professionals to pinpoint exact locations of relevant information quickly. A well-drafted Page-Line Summary should adhere to the principle of conciseness; typically, no more than one summary page should be produced for every five pages of testimony to avoid information overload.

Drafting the Summary: Step by Step

  1. Preparation: Before starting, ensure you have a complete and final version of the deposition transcript. Familiarize yourself with the case and the deposition's context to understand the testimony's relevance better.
  2. Note Any Preferences: If you are creating this deposition summary for someone else, make sure to ask them for any custom instructions: such as preference for how to refer to the attorney and deponent (first person, third person, etc.), formatting preferences, and any important topics or testimony to keep an eye out for. (Check out how Dodonai's automation deposition summary tool enables you to focus the summary on key topics here.)
  3. Page-Line Identification: Start by reading through the transcript and noting down important testimonies. For each relevant piece of testimony, record the start and end by page and line number (e.g., 45:10 – 50:3).
  4. Summarization: Next to each Page-Line identification, summarize the testimony in a concise manner. Make sure to include only information that in relevant to the case. Keep summaries clear and to the point, capturing the essence of the testimony without unnecessary detail.
  5. Formatting: Create a table with at least two columns: one for the citation and the other for the summary. It is recommended to include a third column with a list of the high-level topics, as well.
  6. Highlight Key Testimonies: Consider using different fonts or section headers to separate significant testimonies or themes within the deposition. This can make the summary even more navigable for attorneys looking for specific points.

Here is an example with the 2-column approach:

  • 45:10 – 50:3: Witness recalls the morning of July 7, 2020, witnessing a heated exchange in the parking lot between Davis and Lee. Describes Davis's aggressive posture and overhears threats directed at Lee regarding a disputed contract.
  • 50:4 – 50:21: Records procedural objections from both parties’ attorneys regarding the line of questioning about the contractual dispute.
  • 50:22 – 53:6: Witness details their professional relationship with Davis, noting their role as an independent contractor and not directly involved in the contractual matters.
  • 53:7 – 54:9: Confirms absence during the signing of the disputed contract but mentions a conversation with Lee expressing concerns about the terms.

Your can find more examples with the corresponding transcripts here.

Conclusion

While Page-Line Deposition Summaries are detailed and require a substantial time investment, they offer precise, easy-to-reference documentation of deposition testimonies. If you want to save time and reduce the potential for error, Dodonai's automated deposition summary service can create Page-Line summaries from your deposition transcripts in a fraction of the time.

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