Deposition Summaries · Five Formats, One Reading

The Transcript Takes Weeks. The Summary Takes Minutes.

The transcript comes back from the reporter days or weeks after the deposition, and that wait is the same for both sides. What happens next is not. One reading of the transcript produces five: the page-line table for checking a cite, the same testimony grouped by issue for the causation argument, plain prose for the carrier, a five-minute executive read for the file, and the events in the order they actually happened rather than the order counsel asked about them. Because all five come from that one reading, they cannot disagree with each other, and nobody is sent back to produce a second cut by hand. Every row carries the page:line it came from, and clicking it opens the transcript right there. The days you win back are days to build the defense.

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Deposition Summaries · Five Formats, One Reading● Live
Page-lineTopicalNarrativeExecutiveChronological
201628:1 – 29:25

Prior injuries, claims, and disability benefits.

March of 20184:1 – 6:2

Prior back history and employment duties.

Aug–Sep 201930:1 – 24

2019 prior low back treatment confronted.

9 of 16 rows dated · 7 undated not shown

  • Five formats from one reading, so no two of them can disagree
  • Every row opens the transcript at the page:line it summarizes
  • The summary states what it covered; the chronology counts what it left out

The order things happened, not the order counsel asked

A transcript runs in the order counsel asked the questions. A case runs in the order things happened. When the fight is whether the second injury came before the report, or whether treatment lapsed before the independent medical examination, putting the testimony in date order turns a summary into an argument you can make. Most tools do not offer it, and rebuilding it by hand is an afternoon.

The short version, before you read anything

One of the five is a five-minute read: what this witness gave you, what he committed to that the record can be checked against, and the weakest point for your side, in a few short paragraphs. Every sentence in it carries the line it came from, and anything the transcript will not support is left out rather than softened. When the adjuster calls before you have got through the deposition, that is enough to answer properly instead of promising to call back.

Sorting is a view, never a new opinion

Group by topic and the page:line runs stay in transcript order inside each group, and one click always restores the transcript view. A flat sort would destroy the property that makes it a page-line summary in the first place. No arrangement re-runs the model, so the facts never change because you looked at them differently.

Every line is checkable

Each row carries the address of the testimony it describes, and clicking it opens the transcript at that page:line. A summary you cannot check against the record is a summary you have to re-read the deposition to trust, which is the work you were trying to avoid. Everything read out of the transcript here also becomes checkable against the rest of the file — the records, the bills, the surveillance — which is where a summary stops being a summary and starts being an argument.

Frequently asked questions

What are the five formats?
Page-line in transcript order; topical, grouped by defense issue; narrative prose for client and carrier reporting; a high-level executive summary; and chronological, ordered by event date. All five are produced together from the same reading of the transcript, so they cannot disagree with each other.
Why does chronological matter?
Because sequence decides causation and notice arguments, and a transcript is not in sequence. Ordering by event date puts the injury, the report, the treatment and the examination in the order a fact-finder will consider them.
Does it handle scanned and condensed transcripts?
Yes. The reporter’s own line numbers are used as the citations, so the addresses in the summary are the addresses in the transcript.
What happens to exhibits?
Exhibits are read from the reporter’s markings and listed with their descriptions and Bates numbers, and the exhibits handled in a given passage are shown on that row.
Can I separate liability from damages?
Each row is labelled and the summary can be filtered to either, so the mix tells you what kind of deposition it was.
What can I export?
Hyperlinked PDF and editable Word, in whichever arrangement you are looking at. A filtered export says on its face that it is partial, so a narrowed summary is never forwarded as the whole thing.