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Summarizing a Deposition in Pretrial Discovery Example
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Step 1 Make a clear list of points to be verified. Summarizing a Deposition Step 13 Prepare a digest of the deposition, which should be attached to the deposition. Keep your digest brief. Step 12 Make a list of lines and page numbers where particular answers were important to a point at issue Step 11 Write a brief, more or less chronological narrative of what the witness testified to. Step 10 Ignore the "objections" made by the attorneys while taking of the deposition. Step 9 If applicable, or as an aid to the attorney, draw schematic maps, diagrams or charts to help explain and summarize findings. Step 8 Since the first few pages are typically preliminary statements of identification, you can pass over them. Step 7 Read the testimony in chunks. Don't attempt to absorb the entire deposition at once. Step 6 Make brief notations of your findings relating to the inconsistencies, including line numbers and page numbers involved. Step 5 Reread the deposition which you are summarizing slowly and carefully to get the overall context of the subject matter clearly in mind, paying particular attention to the conversations before and after each point or issue raised Step 4 Read the deposition of other witnesses for comparison, noting the page and line of any statement made which either confirms or contradicts any of the points Step 3 Read through the entire deposition quickly with the objective of finding testimony regarding these points. Step 2 Be specific and identify why each point is important