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Make a clear list of points to be verified.
Summarizing a Deposition
Prepare a digest of the deposition, which should be attached to the deposition. Keep your digest brief.
Make a list of lines and page numbers where particular answers were important to a point at issue
Write a brief, more or less chronological narrative of what the witness testified to.
Ignore the "objections" made by the attorneys while taking of the deposition.
If applicable, or as an aid to the attorney, draw schematic maps, diagrams or charts to help explain and summarize findings.
Since the first few pages are typically preliminary statements of identification, you can pass over them.
Read the testimony in chunks. Don't attempt to absorb the entire deposition at once.
Make brief notations of your findings relating to the inconsistencies, including line numbers and page numbers involved.
Reread the deposition which you are summarizing slowly and carefully to get the overall context of the subject matter clearly in mind, paying particular attention to the conversations before and after each point or issue raised
Read the deposition of other witnesses for comparison, noting the page and line of any statement made which either confirms or contradicts any of the points
Read through the entire deposition quickly with the objective of finding testimony regarding these points.
Be specific and identify why each point is important
