April 18, 2024


The objective of a deposition summary is to present a condensed version of the deposition transcripts where key points are summarized and referenced with their corresponding page and line number from the original transcripts.

There are three types of deposition summaries:
1.  page-line,
2.  topic-by-topic, and
3.  chronological.

Throughout the litigation process, multiple parties will rely on the deposition summary. Attorneys rely on deposition summaries to prepare for pretrial motions, additional depositions, and trial witness exams. They are also useful for attorneys who could not be present at the deposition.

Before attempting to write the summary of the deposition, the paralegal or the summarizer should keep these 3 basic steps in mind:

1. Reading the Transcripts: Focusing on questions asked by the attorneys and the witness’s responses.

2. Annotating Key Points: This includes highlighting the key points that need to be included in the summary.

3. Summarizing Key Points: This includes organizing the key points in the format of a chart, including columns like “Testimony,” “Topic,” and “Page/Line.”

Writing a summary is ultimately about prioritizing information. There should not be any unrelated details in the summary, and it should reflect the focus of the deposition.

As a rule of thumb, well-written summaries should be able to convey 5 pages worth of testimony in a single page of summary.