Before heading to trial, you need a strategy to help you get your information together. Deposition summaries help you prepare for potential cases or an out-of-court settlement by knowing the discovery process. Here are some tips to help you improve your deposition summaries.
Understand the Law
Without a solid foundation in law, it’s hard to write depo summaries. Attorneys need to know every brush of the law to ask the right questions during a deposition. Nuances can help guide the litigation in their favor.
When you have a solid foundation of the law, it helps you develop a better case theory. From that point, you can start gathering evidence to back up your points. Not to mention, flexibility is key to success.
Flexibility in questions and writing the summary can help as specific things evolve in the discovery process. You never know if the deposition may take over 10 hours in 2 separate sessions, which could have slight differences to help with developing your theory.
Keep order throughout the deposition, from having your questions in a specific sequence to outlining the information.
When you organize the topics you want to cover, you save lots of time. Also, you can help weed things out and clear things up as you go. As a result, you’ll save the firm and your client money.
Additionally, a detailed outline helps you cover the bases. You don’t leave any stone unturned to help you create a better case theory to prepare for trial or motions practice.
Of course, you want to use your time wisely to get the most out of it. Instead of breezing through each question, take a little time to hear everything out. You want to be clear on everything you hear so that it doesn’t bite back later at trial.
It’s great to have an outline, but don’t stick so closely to it that you neglect to note things that may challenge your theory. Think about the overall impact on the case you may have through what you heard and wrote in the deposition. Although the fine details count, always have the bigger picture in mind. The unexpected moments may create a better digest.
It takes time to write up the perfect deposition summary. Take your time to get what you need to create something that will help you develop a stronger position in a potential case.