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deposition-summary-exhibit-index

Produces a topic-based U.S. deposition summary with page/line citations and a keyed exhibit index linking testimony to documents. Use when creating deposition digests, exhibit-linked summaries, key document indexes, or discovery testimony maps in commercial litigation.

personAuthor: jakexiaohubgithub
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Deposition Summary with Exhibit Index

Topic-based deposition summary with integrated exhibit index, precise page/line citations, and neutral testimony characterizations.

Quick Start

Gather before starting:

  • Full deposition transcript with page/line numbering
  • Exhibit list with IDs/labels (filenames or Bates ranges)
  • Witness name, role, date, parties, and caption block
  • Any protective order or confidentiality designations

Workflow

1. Cover Block

Include: caption (case name, court, case no.), witness name/role, deposition date, counsel for deponent, reporting service, preparer, and preparation date.

2. Topic Summary Table

| Page/Line Range | Topic Summary | |---|---| | p. 12:3–18:22 | Topic: Formation of Master Services Agreement. Neutral 2–3 sentence summary with key admissions/denials. Cite critical statements by page/line. Reference exhibits inline: "Ex. 12 (Invoice 1043)". | | p. 19:1–24:6 | Topic: Scope of Services and Deliverables. Note uncertainty or evasive answers. Link discussed exhibits. |

Rules:

  • 2–3 neutral sentences per topic; no legal conclusions
  • Cite page/line for critical admissions or contradictions
  • Use specific, descriptive topic titles
  • Split rows when testimony shifts subtopic
  • Exhibit format: Ex. 12 (Invoice 1043) or PX-12 (Invoice 1043)

3. Exhibit Index

| Exhibit | Description | Testimony Page/Line | Witness Characterization | |---|---|---|---| | Ex. 12 | Invoice 1043 dated 3/5/2023 | p. 45:2–46:20 | Identified as company invoice; reflects services rendered |

Rules:

  • Include every transcript-mentioned exhibit with all page/line references
  • One-sentence authentication/characterization summary
  • Map informal exhibit references to correct IDs

4. Key Admissions / Contradictions (Optional)

Include only if requested. Use exact citations:

  • Admission: "No written approval existed for change order." (p. 78:4–10)
  • Contradiction: "Claimed no notice of default; later admitted receipt of 6/2/2023 email." (p. 102:11–16; p. 148:3–9)

5. Output

Deliver as DOCX and PDF with hyperlinks to exhibits and transcript anchors. If linking is infeasible, include file paths or document IDs in brackets.

Pitfalls and Checks

  • Never guess page/line ranges—use exact transcript references only
  • Never add exhibits not discussed in the transcript
  • No advocacy or legal conclusions in summaries
  • Flag privilege or confidentiality issues; do not reproduce protected content
  • Note gaps explicitly if transcript is incomplete or exhibits are missing
  • Confirm compliance with any protective order or redaction protocol
  • Mark uncertain citations or exhibit IDs with [VERIFY]

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