Deposition Summary http://www.ehow.com/how_8378538_draft-deposition-summaries.

html How to Summarize a Deposition Transcript By Michael Staib, eHow Contributor A deposition transcript contains the verbatim testimony of witnesses, including all facts and questions resulting from interrogation not conducted in court, tha t transpired during deposition. Depositions serve as direct pre-trial evidence f or lawyers, specifically litigators, to harness in court. Summarizing a depositi on transcript remains easy to draft, requiring only general understanding of the most immediately material facts that ensued during deposition. Deposition summa ries seldom exceed four pages and usually range between one and two, depending u pon the volume of information. Indeed, deposition summaries demand no greater kn owledge than a general ability to read, brief and simplify material in the most succinct manner possible. Instructions Read the Deposition Read the deposition with an active, engaged mind. Ask yourself who, what, where, when, and why to determine all relevant facts. Overlook extraneous details, such as immaterial questions and information not ne cessary in comprehending the case. Keep a pen or pencil on hand and scan the document. If you feel overwhelmed with information, lightly mark each sentence as you read it to remain actively engag ed. This action keeps the brain sufficiently stimulated to retain information, w hile minimizing fatigue. Take inventory of the facts. Also, though not necessary, if you feel perplexed b y the voluminous data of detail presented, consider annotating the deposition. I f you feel comfortable comprehending the content, just keep reading and assimila ting the facts. Use whatever strategy that works for you to grasp the material. While annotating facts, remember to follow the strategy specified in Steps 1 and 2. Again, recal l the Five Ws, (Who, What, When, Where, Why). Stay terse and to the point in your analysis. A succinct deposition summary seld om surpasses four pages in length. Translating Information Begin writing your summary by translating the information you read onto paper. I f you briefly annotated the facts, incorporating all relevant questions, names, people, addresses, dates, locations, deaths, actions and negligent conduct and/o r other evidence germane to your case, then translating information will remain simple for you. Substantiate annotations by reviewing/re-reading parts of deposition, perusing p ages with all the sideline descriptions you included and incorporating all unans wered assumptions missing from your summary. Consolidate facts. If you thoroughly understood the material without annotating it, then your job remains equally easy. You may recall the information from memo ry to organize summary. Summarize the deposition. Remember the areas/pages you perhaps marked, briefly r eview any critical pieces of transcript and proceed with your summary. Open a new Microsoft Word document to start your summary. Entitle it "Deposition of (whoever)," date the case and follow the suggestions discussed in Step 1. Go to "File" at the top left-hand of your screen, scan tab and click "Save As" to save your document. On Word 2007, access this icon under the Windows icon tab, l ocated at your top left-hand corner as well. Save it as "Deposition of (whoever) " and/or some other title you deem appropriate/easy to identify. Begin translating all relevant information onto your Microsoft Word document in clear, comprehensive sentences. Follow the three S's of writing mechanics---simp licity, succinctness and specificity in sentence structure as you compose your d eposition summary. While writing, remember to periodically save your document an d thereby prevent any loss of significant information. Under "File," listed abov e "Save as," click "Save." You may also use the little disk icon on your top lef

t-hand corner, if you feel comfortable, to save material. http://www.deposummary.com/personal_cs.html PERSONAL INJURY CASE (All names have been changed and case name has been omitted) (Name of Case) Summary of the Deposition of Thomas Eddington, M.D. Taken March 20, 2008 ________________________________________ PAGE: LINE TESTIMONY Examination by Ms. Meadows: 5:15 - 7:21 Profession and Expert Testimony Thomas Eddington, M.D., is licensed in the State of California. He is bo ard certified in physiatrics, which encompasses physical medicine and rehabilita tion. He has been deposed as an expert on over 150 occasions and is familiar wit h the admonitions. 7:22 - 10:3 Retention in Case In 7/07, Eddington was contacted by Carol Powers and asked to participat e in the development of a life care plan for Charles Cahill. He has not been ret ained by Powers on any prior occasions. As of the date of his deposition, he had spent approximately 20 hours reviewing medical records, performing an examinati on of Cahill, generating a report, and preparing a life care document. 10:4 - 10: 23 Exhibit 1 Marked for ID (Life Care Plan) Exhibit 1 is a 7/25/07 document entitled Comprehensive Rehabilitation Evalu ation & Life Care Plan for Charles Cahill. Exhibit 1 was prepared by Eddington with assistance from a colleague, Dr. Phillip Morgan. 10:24 - 12:16 Injuries Sustained by Cahill in Accident In the subject accident, Charles Cahill sustained severe closed head inj uries, facial fractures, a left pelvis fracture, pulmonary injuries and multiple lacerations. Eddington has not attempted to identify or analyze the mechanism o f Cahill's head injuries.

12:17 - 14:9 Coma and Subsequent Condition Cahill was in a coma following the accident, and according to family mem bers, he began opening his eyes five or six weeks after his injuries were sustai ned. Subsequently, Cahill remained in a vegetative state and failed to exhibit a ny type of meaningful behavior. Eddington defines coma as an absence of eye opening, eaningful behavior and purposeful movements. 14:10 - 15:21 Head Injuries As indicated in brain scan imaging, Cahill sustained injuries to the rig ht temporal area of the brain, subarachnoid hemorrhaging around the tentorium, a nd hydroma subdural in the left temporal area. Eddington believes such injuries are consistent with the type of initial forces generated in the accident. Second ary damage was caused by cerebral edema and the cascade release of various chemi cals within the brain. 15:22 - 19:7 Attempts to Elicit Responses from Cahill Eddington examined Charles Cahill on 2/10/07. At the time, Cahill was ly ing in a bed at his mother s home. For the first several minutes of the examination, Eddington attempted to elicit responses to simple questions and commands; howev er, no responses were forthcoming. He then applied visual stimuli, which include d a quick, aggressive hand movement near Cahill s eyes. Cahill blinked, but was unab le to achieve any consistent visual tracking. Eddington concluded that Cahill s eye

blink was an automatic reflex mediated by the brain stem. Cahill was also non-re sponsive to sounds, which included shouting and loud clapping. 19:8 - 22:16 Physical Examination After failing to elicit any significant responses from Cahill, Eddington performed a neuromuscular examination, which included an evaluation of Cahill s cra nial nerves, eye movements, and responses to additional auditory and visual stim uli. He then checked for spontaneous and focal localized movements, performed a sensory examination of Cahill s reflexes, and attempted to determine the extent of C ahill s motor strength and coordination. In total, he spent approximately three hour s with Cahill on 2/10/07.