Deposition Summary

# Deposition Summary

Turns a deposition transcript into a page:line summary organized by topic, with the admissions, inconsistencies and follow-up the trial team needs.

## What to ask for
- The transcript (with page and line numbers) and exhibit list; the exhibits themselves if available.
- Case caption, which side the firm represents, and the claims and defenses (or the pleadings).
- Other evidence to compare against: case chronology, documents, prior testimony, declarations, discovery responses.
- Desired format: topical (default), chronological page:line, or both; any issues to focus on.
- If something is missing, summarize what's given and mark gaps as [MISSING: ...]. If page:line numbers aren't in the text, say so and cite by the best available locator.

## How to work
1. **Read the setup.** Deponent, date, location or remote, who appeared for whom, interpreter, stipulations, whether the witness was designated (entity representative) and on what topics, read-and-sign status and errata deadline.
2. **Background.** Education, employment, role, relationship to parties, preparation for the deposition (documents reviewed, who they met with), prior testimony.
3. **Topical summary.** Group testimony by subject (e.g. contract formation, the meeting on a date, the termination, damages). For each point, state the testimony in one or two plain sentences with page:line. Keep the witness's key words in quotation marks.
4. **Admissions.** Testimony that helps the firm's client or establishes an element, with exact quote and page:line. Note whether the question was clean (not compound or leading on a disputed point) so it holds up.
5. **Unhelpful testimony.** Testimony that hurts the client, with cite and how it might be addressed.
6. **Inconsistencies.** Contradictions within the transcript, and against documents, other witnesses, pleadings or discovery responses. Cite both sides.
7. **"I don't know" / "I don't recall."** Topics where the witness lacked knowledge, and who might know instead.
8. **Objections and instructions not to answer.** Page:line, basis, and whether a motion to compel or further session may be needed.
9. **Exhibits.** Each exhibit marked, what it is, and the key testimony about it.
10. **Follow-up.** Documents identified that haven't been produced, new witnesses named, topics for further discovery, questions for the client.
11. **Errata watch.** Testimony likely to be changed on errata (key admissions, numbers, dates, names) and the errata deadline (to verify).

## Output

**Deposition Summary: [Deponent], [date]**  Case: [caption, no.]  Representing: [ ]

1. **Snapshot** (4-6 lines): who the witness is, overall impression, the three most important points.
2. **Appearances and stipulations** (short list)
3. **Topical summary** (heading per topic; bullets with page:line)
4. **Key admissions** table: Testimony (quote) | Page:line | Supports | Notes
5. **Unhelpful testimony** table: Testimony | Page:line | Issue | How to address
6. **Inconsistencies** table: Testimony | Page:line | Contrary evidence | Source
7. **Lack of knowledge** (bullets: topic, page:line, who else may know)
8. **Objections and instructions not to answer** table: Page:line | Question | Objection | Follow-up needed?
9. **Exhibits** table: Exhibit no. | Description | Key testimony (page:line)
10. **Follow-up items** (numbered)
11. **Errata to watch** (bullets) and **To verify** (errata and read-and-sign deadlines, motion-to-compel deadlines)

## Rules
- Draft for attorney review; attorney work product. Mark it "Privileged and Confidential, Attorney Work Product".
- Errata, read-and-sign and motion deadlines vary by jurisdiction and court and change: list them under "To verify", never state them as final.
- Never invent facts, dates, amounts, case law or citations. Unknown = [MISSING].
- Every summarized point has a page:line cite. Quote exactly; never paraphrase inside quotation marks.
- Summarize what the witness said, not what the lawyer asked, unless the witness simply agreed (then note "agreed that...").
- Don't characterize credibility beyond what the transcript shows; flag demeanor only if noted on the record or in a video.