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Deposition Summaries

Drafting summaries of depositions is an area of responsibility that overlaps with those of paralegals. In some firms, legal nurse consultants draft depo summaries; in other firms, paralegals do. As a new legal nurse consultant, you'll want to at least know the different types of deposition summaries and the circumstances for using them.

First, let's define the term "deposition summary". A deposition summary is a brief, concise statement of the main points of the deposition. There are many different types but the two that I'm most familiar with are page-line summaries and narrative summaries. Each has different uses.

Page-line summaries, as the name implies, refer to the pages and lines in a deposition transcript. Each page in a deposition transcript is numbered and within each page, each line is numbered one through 25 as this sample page from a deposition transcript shows. Print the sample transcript page as well as the sample page-line summary and narrative summary. That way, you'll be able to compare the differences in the summaires.

Page-line summaries identify important points in the deposition by the page and line(s). This type of summary is useful for attorneys who want to skim the summary or compare one summary to another. Page-line summaries can be formatted several ways but they usually include a 3-column table with or without border lines. A variation of the page-line summary is to add a fourth column for the topic of discussion.   If you want additional formats for page-line and narrative summaries, they can be found on the internet.

Narrative deposition summaries are similar to narrative medical summaries. Deposition summaries describe the testimony in a narrative format, often beginning with the deponent's demographic data. The summary then describes the salient parts of the deponent's testimony.  Many insurance adjustors prefer this type of summary.

Because there are different kinds and formats of deposition summaries, consult with your clients to determine their preferences. If you haven't been involved in the case before, also discuss case issues and theories so you'll know what areas to focus on. Before you know it, you'll be a pro at creating depo summaries!

..Katy Jones

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