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3 Methods For Preparing A Deposition Summary

21 November, 2022


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There’s more than one way to skin a deposition. There are three main methods you can use to draft a  deposition summary example. Each has its own advantages and disadvantages, which we will outline below, along with a deposition summary example.

What Is A Deposition Summary?

What Is A Deposition Summary

A deposition summary is objective and concise. The clerical digest of the main points of the deposition transcripts consists of the page and the page line summaries. This is typically formatted and includes the page line exhibit and the summary of the testimony.

For preparing the deposition summary, you can take a paralegal and constantly ask questions from the clients. Every paralegal deposition and transcript is required to be summarized within 8 to 9 hours. But this time can be longer than this or shorter than this.

Here are some of the factors which are influencing deposition summary.

  • The case complexity.
  • The type of deposition summary which you are preparing.
  • The deponent represents as a lay witness or an expert witness.
  • The case knowledge and the other things.
  • The prior experiences of deposition transcripts case handling.

How To Create A Deposition Summary?

Create A Deposition Summary

Now let’s see if you have to summarize 30 or 20 deposition transcripts. What you should do? And how you can easier work and summarize the 20 deposition transcripts. There are many deposition summary software available in the market. You can use software else you can do it yourself.

Here are some of the easy tips which work as guidance.

Method 1: The Page/Line 

The page line method involves writing down the page number and line number of the relevant portion of the transcript and then writing down the key points from that section.

Here’s how the deposition summary works! 

  • Write down the page number and line number of where you want to start taking notes. For example, if you were on page 3, line 5, you’d write down “3-5.” 
  • Then write down what happened in that section of testimony: “The witness said he didn’t remember.” 
  • Continue this pattern until you’ve finished taking notes for all sections of testimony you want to include in your summary. 

Method 2: The Page Summary 

The page summary method of preparing deposition summaries works best when you have a lot of material to read, and you want to make sure that you don’t miss anything important. 

Here’s how it works:

  • Print out the entire deposition summary so that you can mark it up with pencils or pens. 
  • Read through the entire thing from beginning to end, marking down anything that seems relevant, as well as any questions that come up while reading through it. 
  • Once you’ve gone through all of these steps, go back over them again and make sure everything looks good before creating a final copy for yourself! 

Method 3: The Issue Summary 

In the Issue deposition summary Method of preparing deposition summaries, each paragraph is focused on a single issue to be addressed in a deposition. The paragraphs are organized chronologically and sequentially, beginning with the earliest events and ending with the most recent. 

A paragraph may address more than one issue, but each issue should be clearly identified and segregated from other issues being addressed in the same paragraph. The witness’s testimony should be summarized in chronological order, and each fact or opinion must be set out separately. 

What Are The Tips For Litigation Paralegal?

Litigation Paralegal

The deposition summary will go to add value to the cases. And here are some of the tips which you can apply for the litigation paralegal. And these factors also influence the  20 – 25 pages of deposition transcripts.

  • The type of witness lay and the expert.
  • The paralegal’s experience level is also influencing the time.
  • The type of summary is prepared along with the page line, summary, and summary issues.

These are the easy tips that you can follow to create a deposition summary. You can apply these tips and create a deposition summary.


Ultimately, there’s no “best” method for drafting the deposition summary. It all depends on your own writing style and the needs of your client. However, if you’re just starting out as a legal writer, you may want to choose a method that maximizes your control over every aspect of the process.

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Arnab Das is a passionate blogger who loves to write on different niches like technologies, dating, finance, fashion, travel, and much more.

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