Tips on Depo Summary

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Tips on Depo Summary

Postby TFALAWL » Sun May 31, 2015 4:00 am

Hi, I'm a 2L SA. I was wondering if anyone has tips on how to "efficiently" do a depo summary. Thanks!

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Re: Tips on Depo Summary

Postby OneMoreLawHopeful » Sun May 31, 2015 5:59 am

TFALAWL wrote:Hi, I'm a 2L SA. I was wondering if anyone has tips on how to "efficiently" do a depo summary. Thanks!

Was your firm taking or defending?

If your side was taking the depo then someone should have a depo outline prepared which laid out the goals of the depo (what you wanted the guy to say, what "control" exhibits you were going to use, etc.). You can take the outline shell and then fill it in with summaries of what was actually said - but keep in mind the witness was likely coached and gave answers that are open to interpretation; in that case use exact quotes for the answers to the critical Qs, otherwise your summary may inadvertently over promise in a way that the transcript then under delivers. If you start with the pre-built outline then you can save a lot of time on organization and such.

If you were defending, then you need to identify the subjects that your opponent was after, and summarize what the themes in the questions were. (I.e. "Plaintiffs questions were aimed at getting witness to commit to a date on which he first learned X.") if a question seems to have been killer, then you need to use exact quotes for the same reason as above - you need to let the reader know exactly what your side is tied to now. If you focus on the topics of the depo to create an "outline" of sorts, that will help you to contextualize notes quickly and get through it faster.

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