If you’re a lawyer, paralegal, or involved in a legal case, you’ve likely heard people talking about depositions. A legal deposition is a sworn, out-of-court testimony that can be used in court as a written transcript or summary, usually conducted by a lawyer with no judge present. These documents are a critical part of the legal infrastructure of Western countries, and it’s important to fully understand the different types of deposition summaries, to make sure that any legal court case you are involved with goes as smoothly as possible.

Since depositions can easily become lengthy and quite wordy, it’s important to be able to summarize them quickly, accurately, and professionally. Proper deposition summaries must be unbiased, accurate, and typically reduced from the original by a ratio of between 10-15 to 1, meaning that for every 10-15 pages of raw, unedited transcript, your final deposition summary will have about a page of relevant and easy-to-absorb material. In this article, we’ll cover the two most common types of depositions, and afterward, the various forms of deposition summaries which can be prepared by a paralegal or other assistants.

Discovery Deposition

A discovery deposition will likely contain broad questions that gradually narrow down as the lawyer or attorney focuses on and finds out more about the case. These are often used in cases where the person being interviewed was reluctant or unwilling to talk to a lawyer without a subpoena and might have been withholding information. Discovery depositions are an extremely common legal tool used before cases and are an effective tool in the lawyer’s toolbox to crack witnesses or get information from anyone involved in a legal case.

Preservation/Evidence Deposition

A different type of deposition is a preservation deposition, where the lawyer wants to preserve evidence from a witness that may be unable to testify in court. This can be due to illness, death, or imprisonment. This type of deposition can be used to perform the same functions as a discovery deposition, with a broader ability to find and utilize witnesses.

Types of Deposition Summaries

No matter which type of deposition and the format it is conducted in, such as oral, written, or video format, the deposition will likely then have to be condensed into a deposition summary, of which there are several types: page-line, topic-by-topic, and chronological.

Page-Line Deposition Summary

This format of deposition summary is one of the most popular but also one of the most time-consuming. It requires someone with legal experience to go through the document, as well as a summary that is aligned with the line and possibly reference exhibits. This type of summary produces a document that is easy to use and reference, and it will contain information that presents two numbers like this: “30:15”. This would indicate that the relevant information is contained on page 30, line 15.


This type of deposition summary is more broadly organized and efficient to compile than a page-line summary, but can contain less information and is not quite as comprehensive. The goal of this type of summary is to provide the reader, usually a lawyer or judge, with a quick overview of relevant facts and topics, as well as to be easily browsable for information.


When it comes to criminal cases and a defendant trying to prove their innocence, or a prosecutor trying to establish guilt, the timeline of events is critical. Having the testimony of events and actions in the correct order and the timeline established as firmly as possible is of the utmost importance to these cases, and this is the goal of a chronological deposition summary. This way, the court will be able to have the fullest understanding possible of the events they are discussing and use the information to make the correct decisions and rulings

How Are Deposition Summaries Prepared?

The process of preparing these documents varies between different law firms or lawyers. Usually, a paralegal or administrative staff member of a law firm will take their time going through the original transcript and use their knowledge and experience to annotate or demarcate important sections of the text, which they will then go back and summarize at the end. This document can be prepared with inter-document links for easy access, and relevant information about the case or other precedents will be used to make sure no important points are missed.

To figure out which type of deposition summary will work best with your case, it’s preferable to consult with a lawyer or legal firm and let them handle it. Although they are not mandatory, a well-formatted and concise deposition summary can have a profound impact on how a presiding judge sees your case and the overall outcome of the proceedings. For these reasons, the best step to take after performing a deposition is to use professional deposition summarizing firms or workers to quickly, affordably, and easily summarize the facts into a brief document that can be read or presented to a judge without superfluous or unnecessary information.

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