Deposition Summary with Key Document Index

Deposition Summary with Key Document Index

Transforms a deposition transcript into a topic-based summary table with integrated exhibit cross-references for rapid navigation between testimony and documentary evidence.

Prerequisites

• Complete deposition transcript with page and line numbering
• Exhibit list and files referenced or marked during deposition
• Case context: party names, key contract sections, claims at issue

Workflow

1. Review Transcript

Read the full transcript and identify:

• Natural topic breaks (explicit subject changes and thematic shifts)
• Every exhibit reference — formal ("Exhibit 3") and informal ("the email we just reviewed")
• Key admissions, contradictions, evasive answers, and authentication testimony

2. Extract Topics

For each topic, capture:

3. Build Exhibit Index

Create a master exhibit cross-reference table:

4. Assemble Summary Table

Primary deliverable — two-column table:

| Transcript Cite | Topic & Summary |
|-----------------|-----------------|
| pp. 12:4-18:22  | **Formation of the Supply Agreement**
|                 | [2-3 sentence neutral summary]. See Ex. 3
|                 | (Supply Agreement, discussed at 14:8-15:2).
|                 | Notable: Witness admitted not reading §4.2
|                 | before signing (15:18-22). |

Within each summary cell:

• Embed exhibit references discussed during that testimony
• Cite specific page:line for key admissions
• Use hierarchical headings for major topics vs. subtopics

5. Output

Produce both:

• DOCX — formatted table with hyperlinks to exhibits and transcript locations
• PDF — preserved hyperlinks, full-text searchable, locked for filing

Key Rules

• Neutral tone only — summarize what the witness said, not what it means for the case
• Specificity over brevity — "Witness denied receiving the October 14 demand letter" not "Witness denied receiving correspondence"
• Organize by substance, not questioner — consolidate redirect and direct testimony on the same topic under one heading
• Capture authentication testimony — note when witness identifies, authenticates, or disputes a document
• Flag evasive responses — mark non-responsive answers, memory claims, and qualified answers

Quality Checklist

• [ ] Every exhibit mentioned in testimony appears in summary and exhibit index
• [ ] No exhibits referenced that weren't actually discussed
• [ ] All page:line citations verified against transcript
• [ ] Summaries reflect actual testimony — no interpretation or legal conclusions
• [ ] Topic headings specific enough for at-a-glance navigation
• [ ] No privileged communications or work product included
• [ ] Hyperlinks resolve to correct targets