Techniques

Digesting Depositions and Other Documents

Techniques for digesting depositions

• Study the file

• Review outline of the questions used at the deposition

• Skim the entire deposition first

• Draft a topical outline or tentative table of contents

• Schedule blocks of time to do actual digesting

• Compose summary in electronic form

• Be as concise as possible

• Use abbreviations and short forms as much as possible

• Be accurate about what witnesses said

• Use subheadings frequently and write in short paragraphs

• Use page and line number references in the margins

• Include all dates exactly as mentioned

Types of Deposition Digests and Indexes

• Chronological

A chronological deposition digest would present a summary of a witness's deposition testimony in the order that events occurred, detailing key facts and statements as they unfolded in the timeline of the case, typically including page and line numbers from the transcript for reference; for example, "On June 1st, 2023, the deponent stated (pg. 25, line 10) that they arrived at the worksite and noticed a damaged piece of machinery, which they immediately reported to their supervisor."

• Topical

instead of a chronological approach, this format clusters deposition testimony into distinct topics or themes relevant to the litigation. This allows legal teams to quickly home in on specific aspects of a case without having to wade through pages of unrelated information.

• Narrative

A narrative deposition summary is a concise, story-like account of a deposition that highlights the most important points and testimony. It's a useful tool for providing a clear overview of a deposition to clients, insurance adjusters, or other team members.