An accurate deposition summary enables attorneys to clearly communicate the main points in a deposition transcript.

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Types of Deposition Summaries and Tips to
Prepare Them
An accurate deposition summary enables attorneys to clearly
communicate the main points in a deposition transcript.

2. www.mosmedicalrecordreview.com 918-221-7791
Deposition summary preparation is one of the important medical records review
services that attorneys require while handling a case. Deposition transcripts may
include hundreds of pages of transcribed conversations, which makes reading
these transcripts a time-consuming task for attorneys. Depositions provide
opportunities for both the plaintiff and the defense side to find out more about
witnesses and what they would be able to testify about at trial.
Three Types of Deposition Summaries are -
1. Chronological Summary – Here, facts are presented in a chronological order
and are important in personal injury and criminal cases.
2. Page-Line Summary – This page-by-page summary is aligned with the page-
line and exhibit reference and is preferred in cases involving financial
transactions and in commercial litigation.
3. Topic-by-Topic Summary - These topical summaries provide the reader with
a quick overview of the deposition based on the topic or subject and are
the preferred format in workers’ compensation, and auto accident cases.
Consider these tips, when preparing a deposition summary
Summarizer should -
• Read the entire deposition, as it is important to understand what mattered
most to the attorney taking the deposition and get a clear picture of what
the witness had to say
• Note down important questions and answers in the testimony to save a lot
of time later on when actually making a summary

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• Keep summaries accurate and concise to quickly state the general theme of
the deposition and what was obtained
• Be consistent to check with the attorney what format they want the
summary in
• Include additional discoveries that may be helpful to the attorney
• Consider separating different sections and subsections by which the
attorney is performing the examination
• Proofread the deposition summary thoroughly to avoid errors and
confusion
Deposition summaries are important for a successful motion practice, preparing
for ensuing depositions, and direct and cross examinations of witnesses at trial.
Depositions are also useful for judges to use the summary to prepare a summing
up statement or use it during the trial. To get objective, accurate and timely
deposition summaries, attorneys can consider partnering with a medical chart
review company that has relevant experience in the industry.