The Federal Rules of Civil Procedure define a deposition as a process in which one party asks the other party or witness questions under oath.
A summary of the deposition is a written record of the questions and answers. A deposition summary example provides an account of any objections raised during the deposition. The judge and jury use the deposition summary to determine what evidence will be admitted at trial.
Deposition summaries are important since they preserve evidence that has been gathered, and they allow attorneys to review all information obtained during the discovery process.
The following tips can help you prepare a more effective summary:
Decide on a format in advance
Creating a template can help you with future summaries. Use the same format each time to become second nature and not forget important components, such as objections.
This also saves time because you do not have to start from scratch with each new summary.
Skim the transcript
Before going through the transcript in detail, skim it once to get an overview of what has been said in each section.
This will give you context for when you delve further into the transcript and will help you to identify critical points.
Edit for accuracy
You should only include facts conveyed by witnesses during their depositions. Do not include personal opinions or your thoughts about what was said.
The best way to ensure accuracy is to listen carefully while taking notes during the deposition and then type up your notes as soon as possible while they are still fresh in your mind.
Annotate the key statements
As you go through each section of the deposition, be sure to annotate as much as possible, but focus on key phrases that you think may be important later on in your case.
It’s better to have too much information than too little.
Decide the integral parts of the deposition
Lawyers should decide beforehand what parts of the deposition are relevant and important to use during trial.
They might highlight those parts with a highlighter or note them in the margins while reading the transcript, if they are using a written deposition.
It is essential to have all deposition summaries ready for the attorney, but there is never enough time in a busy legal secretary’s day.
Scheduling and good organization will play a huge factor in creating quality summaries on a timely basis.
The more prepared you are before starting, the easier it will be to meet deadlines.
Keep these tips in mind when preparing deposition summaries to ensure that you can make the deadline and produce a product you will be proud of.