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Deposition Summary:


What is a Deposition?
A deposition is the taking of an oral statement of a witness under oath, before trial.
It has two purposes:

  • To find out what the witness knows, and
  • To preserve that witness' testimony.

In a deposition, an attorney can ask a number of questions. Not all of these are directly relevant, and they can be repetitive in nature, depending on the style an attorney uses. At the deposition, a clerk records the testimony, and the law firm may also use video and tape recording. The end result is a very large volume of data, all of which can be useful. Having a deposition summary as a shortcut to the key points may be important for people preparing for trial, as it can help them decide on trial strategies like who to call as a witness and what kinds of questions to ask..

Preparing Deposition Summary
A deposition summary is a brief document going over the basic information from a deposition, testimony taken before a trial to help legal teams prepare. Preparing a deposition summary requires going over the testimony, taking ample notes on the substance of the deposition, and thinking about the most important information that comes up. Many law firms have a standard template. They want people to convey basic information, including the date and time of the deposition, and who was present.
Deposition Summarizer may break it into a series of headings covering specific topics, and can include a table of contents so attorneys can reference the direct testimony while they read.

A deposition summary provides a gist of what happened during the deposition. Citations can be added to back up the claims. Extraneous and repetitive aspects of the deposition are not a part of the summary, as the goal is to cut to the core of the testimony. An attorney may think about the information they would find most relevant and useful when working on a case of this nature. This can help them determine what to include and what to leave out.

A second party may review the testimony and the deposition summary for accuracy. People want to make sure the testimony is represented accurately and appropriately in the summary, and they also look for holes in the content. Since people may rely on the summary for making legal decisions, it is important to avoid leaving information out in the interests of brevity.

Things Required -

  • Transcript of the deposition.
  • Word processing software.

Instructions for Summarization

  • Taking Notes - Talk to the lawyer who took the deposition. Ask her if there is specific testimony that she wants you to look for in the deposition and note in the summary.
  • Read the party's pleading - the complaint, if you are summarizing the deposition of the plaintiff or plaintiff's witness, or the answer, if you are summarizing the deposition of the defendant or the defendant's witness. As you read the pleading, focus on the allegations in the pleading and the facts the party has alleged in support of those allegations. (if provided by the attorney)
  • Deposition Summary Format - Open a new document in a word processing application.
    Use the required deposition summary format.
    1. Page by page deposition
    2. Chart summary deposition
    3. Customized depositions
  • Read the deposition transcript - As you read, analyze the witness's testimony for information the deposing lawyer asked you to locate and for other information that may be relevant, based on your review of the pleadings.
  • Type relevant information in the summary document - For example, if the witness testifies that she previously gave a deposition in another civil lawsuit where a passenger in an automobile accident sued her, type "Previously deposed in 2001 as defendant in MVA litigation." (MVA is an abbreviation for motor vehicle accident.) Here, this information is relevant because the witness's sworn testimony in the prior lawsuit may be used to impeach her testimony if it is inconsistent with her testimony in the case at hand.
  • Include breaks - noted in the deposition transcript in your summary; for example, a lunch break during an all-day deposition. The lawyer may recall that the witness made an important admission after the lunch break, so including breaks in the summary will help the lawyer find the admission. (As per instructions only)
  • Recheck once done with summarization – Attorneys should re-check deposition with regards to the content, accuracy, grammatical, spelling and formatting issues before submitting it to the concerned Head.


Delivering high-value deposition summaries involves both litigation proficiency as well as strong English writing skills. A blend of litigation experience and first-rate synopsis writing skills make our team very effective in providing high-value deposition summaries.
Aeren LPO has its own team of experienced attorneys, to perform the necessary analysis and summarization to produce quality deposition transcripts. Aeren LPO Deposition Summary process reduces testimony to key facts providing a well articulated summary of main events, dates, and witnesses; eliminating erroneous information. Our deposition summary team enables you to cut down the turnaround time so that the attorney gets to review the same at the earliest.
Our team will work closely with you and your team to deliver deposition transcripts in the format of your choice along with other relevant information. Every deposition summary is accurate, concise and easy to understand.

Deposition Summary Process Flow is as per below:


  • Our extensive domain expertise helps clients achieve rapid and sustainable cost savings while facilitating improvements in efficiency and minimization of risk. We offer our clients:

  • India based teams
  • Professionals with more than 8 years of experience
  • Repeatable, defensible, efficient and scalable processes
  • Free pilot project assessment
  • Outstanding Project Management
  • Six Sigma accountability
  • Lowest possible costs
  • Security and Confidentiality ISO Certification
  • Meet ever-tightening deadlines
  • 24/7 resources available and accessible
  • We attract the best and brightest attorneys in the industry, and conduct training in accordance with the codes of professional conduct and ethics governing the practice of law in the US and the UK

    We present clients with a highly educated and trained legal support team including Certified ESI processors, attorney reviewers, project managers and litigation analysts. We operate a state-of-the-art infrastructure and strict adherence to Six Sigma processes.

  • Permanent full-time legal associates
  • ISO 27001:2005 certification
  • Conflict-checks performed on each legal associate
  • On-site, multidisciplinary management professionals
  • 24-hour security sentry
  • CCTV security cameras
  • Secure document destruction process
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  • Physical on-site security
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ISO/IEC 27001 formally specifies a management system intended to bring information security under explicit management control.


HIPPA establishes standards for EDI,secuity,and confidentiality of all healthcare-related data.


Deposition Summarization is a very important document in the hands of attorneys. It forms a gist of the statements deposed by a witness. Thus, a summary should always be accurate, depict true information, and avoid repetitive information. There should also be no spelling errors, grammatical, punctuation and formatting errors in the final deposition summary.

Below are few quality parameters taken care at AerenLPO:

  1. Accuracy – The gist or summary should provide accurate information as depicted in the original transcript.

  2. Sentence formation – Sentence formation is one of the key aspects to good summary. The sentences formed should be very clear and should not be ambiguous.

  3. Format - The summary should always be in proper format with the required headings, page numbers, line numbers etc.

  4. Grammar and spacing – A summary needs to be grammatically correct. An incorrect grammar is always a look down upon thing.

  5. Spelling – Spellings in a deposition summary must always be correct. Incorrect spelling is always a BIG NO. Above are the basic parameters that need to be kept in mind while doing and evaluating deposition summaries.