Organize Your Deposition Abstracts by Issue, Not by Page Number

One of the problems with assigning the task of abstracting a deposition to a lawyer or paralegal who is not familiar with the case is that you'll often end up with a page-by-page recounting of the deposition testimony that, though shortened somewhat, still contains way too much information in a way that remains hard to skim. It's one of the reasons why, when time permits, I'd rather abstract depositions myself.

However, I don't arrange the abstracts page-by-page. Instead, I do it by topic or issue. For example, in a recent overtime case seeking overtime for a class of insurance adjusters, my deposition abstracts were organized by issue, with headings such as job duties of insurance adjusters, use of discretion and independent judgment, company structure, numerosity, common questions of fact and law, and so on. I then copy-and-pasted the witness's most important deposition testimony to the issue outline with a page citation.

When the same case issues are used for abstracting every deposition in a case, it makes finding pertinent information a breeze. And if you use software like CaseMap, it's possible to view deposition summaries both page-by-page or by issue, changing between the views with a click of the mouse.

Comments

[Yeoman]

Excellent idea. I think I'll try it.

I've always had it done by number, which does leave you furiously thumbing through the synopsis at trial trying to find that point you know is in there.