Deposition Summary Narrative

• Case caption (style of cause, court, docket number)
• Deponent name and litigation role
• Date, location, attorneys present with affiliations
• Privilege notice: "Prepared at the direction of counsel. Attorney Work Product — Privileged and Confidential."

2. Executive Overview (1–2 paragraphs)

Cover key topics, most significant admissions, credibility concerns, and impact on case theory.

3. Narrative Body

Organize by topic, not Q&A order. Typical sections: Background & Qualifications, Events Leading to Incident, The Incident, Damages & Injuries, Medical Treatment, Employment & Financial Impact. Adjust to fit case type.

Per section:

• Write flowing prose — never reproduce Q&A format
• Cite immediately after each assertion: (78:3–15)
• Flag admissions: "Significantly, the witness acknowledged..."
• Flag contradictions: "This conflicts with the affidavit stating..."
• Flag memory gaps: "Witness claimed no recollection of X despite prior specificity about Y (167:12–168:3)."
• Note demeanor shifts or evasiveness inline

4. Exhibit Log

5. Privilege & Objection Notes

• Instructions not to answer (question, objecting counsel, basis)
• Privilege assertions (attorney-client, work product, FRE 408)
• Material objections on form, foundation, or scope

Pitfalls and Checks

• Always cite: never paraphrase a critical admission without (page:line–line)
• Length target: ~25–33% of transcript length; completeness over brevity
• Accuracy: do not characterize beyond what the transcript supports; summary must be defensible to opposing counsel
• Work product header: repeat on every page with case name and deponent
• Follow-up queries: cite both summary location and underlying transcript page/line
• Jurisdiction: follows US federal and state civil litigation conventions