How To Write A Good Deposition Summary

December 3, 20220

Have you ever been involved in a deposition? If so, you should know the importance of a deposition summary.

A deposition summary is important because it contains the relevant details from the witness in a case.

When you’re writing a good deposition summary, it’s important to make sure that you’ve done your best to capture what the witness said word-for-word.

This will help ensure that there are no discrepancies between what was said during the deposition and what’s written down in your summary.

What Is A Deposition Summary?

A deposition summary is a document that summarizes the testimony and evidence presented during a deposition. It’s usually created by an attorney or paralegal who is working on a case, and it’s meant to be used by attorneys when they’re preparing for trial.

What Is The Purpose of A Deposition Summary?

The purpose of a deposition summary is to make it easier for attorneys to prepare for trial by giving them all the important information from depositions in one place. They don’t have to read through all the transcripts and reports; they just need to read this summary.

Key Features of A Deposition Summary

Deposition Summaries are a great tool for attorneys to use in the litigation process. They provide a summary of the testimony from a deposition, along with key evidence that was introduced during the deposition.

The summary should include a description of what happened during the deposition, including:

  • The date and time of the deposition
  • A list of all attorneys involved in the case, including their addresses and phone numbers
  • The name of each party involved in the case
  • The name of each witness who testified during the deposition
  • A brief description of what took place during the deposition 
  • What questions were asked by each side?
  • How did the witness respond?
  • Was there any cross-examination?
  • It should include any exhibits or documents that were used during questioning.
  • Include any objections made by counsel during questioning and whether the court reporter or judge presiding over proceedings sustained or overruled them.
  • It should include any questions asked by each side’s attorney and whether they were answered directly or evasively (e.g., “I don’t recall” or “I’m not sure”).

The Importance of Writing An Accurate Deposition Summary

When you are preparing for a deposition, it is important to start with an accurate summary of the events in question. This can be helpful in many ways, including:

  • It will help you prepare for your own testimony by giving you a clear understanding of what happened during the incident or event in question.
  • Allows you to make sure that your client understands what happened during the incident or event in question, so that they can give their own testimony as accurately as possible.
  • It will allow your client to prepare any questions they may have about the experience so that they can ask those questions during their deposition.
  • It will allow opposing counsel to understand what happened during the incident or event in question, so they can prepare their own questions accordingly and make sure they are getting all the information necessary from their own witness.

7 Steps To Write A Good Deposition Summary

  1. Make a list of all the important facts you want to include in your summary.
  2. Write down the main points of each witness’s testimony, including any important information that was left out of their direct examination.
  3. Note down any questions that were asked but not answered during direct examination, and make sure those questions are answered in your summary.
  4. Write down any objections made by opposing counsel during direct examination, even if they were overruled by the court or withdrawn by opposing counsel later on in cross-examination.
  5. Write down anything that was said by a witness that would be helpful to write down, but isn’t necessarily important enough to include in your summary (like “um”s and “uh”s). These should be noted at the bottom of the page as “unclear” or “inaudible.”
  6. Note who said what so you can refer back to it later on if needed (e.g., “John Smith testified that he saw the defendant stab the victim”).
  7. Make sure you cite properly all facts using footnotes or endnotes (e.g., John Smith testified that he saw the defendant stab victim [footnote 1]).

Why You Should Hire An Expert To Write Your Deposition Summary?

There are many reasons why you should hire an expert to write your deposition summary. 

The first reason is that they know how to do it. They have been doing this for years and know what the best way to summarize a deposition is. This can be helpful for any company because it will save them time and money in the long run.

Another reason why you should hire an expert is that they know how to write a summary that will help you win your case. They will write a summary that shows what was said in the deposition and helps you convince a judge and prove that it happened or didn’t happen.

The last reason why you should hire an expert is that they will make sure that everything is accurate and correct, which is very important when writing a deposition summary for court purposes.

Final Thoughts on Deposition Summary

It’s important to remember that a deposition summary is not just a summary of testimony—it’s also a representation of that testimony. In other words, if the summary isn’t done well, it can be more damaging than helpful. 

If you’re thinking about writing a deposition summary yourself, it’s time to reconsider. You can’t do this alone. It’s not enough for you to understand the deposition—you need to know how to put it in words that will be easy for others to understand.

The best way to ensure that your deponent’s information is accurately conveyed is by hiring an expert who knows how to write professionally and creatively.

Author bio-

Sheila LaCivita is the owner of 4 Corners Depo. She got a paralegal degree with distinction from UCLA and has been helping lawyers with deposition summaries. She wants to share her knowledge and experience with others.

Leave a Reply

%d bloggers like this: