Tuesday, April 8, 2014

How to Have Fun Summarizing a Deposition

Use Keywords When Summarizing a Deposition.  Just kidding.  Summarizing a deposition is not fun.  However, I don't know how someone can summarize a deposition without a list of keywords.  Keywords are the elements of a cause of action, background, credibility, etc. You can use a table to enter your summary or you can insert a keyword at the beginning of each statement in the deposition that you want summarized.  This groups all facts relating to each element of your case. These two methods are explained below.

Using Paragraphs to Sort Keywords in Word 2007.  Here is a typical deposition summary.  The keyword is first.  The summary is next.  Then the page and line numbers are in parentheses.


Entity,  Bob is the president of four corporations:  Noma Group, Noma Properties, Noma Management, and Noma Construction and Development (1/19).

Agency.  Ed Toma was President before (3/14).

Assent.  Bob never saw the Joint Check Agreement before (5/14).

Agency.  The Joint Check Agreement "appears to be" signed by Mr. Toma's secretary, Sherry (9/24).

Agency.  Noma Construction and Development was the operating entity that ordinarily signed these kind of joint check agreements (10/23).

Consideration.  Bob doesn't remember if Plaintiff's equipment went into Defendant's project (11/23).

Assent.  Bob has no way of knowing if Phase II meant the 2nd cul de sac (12/16).

Select all, then Home, then paragraph then sort then makes sure the box says “sort by paragraph,” Text and Ascending—then click ok
You will get this

Agency.  Ed Toma was President before (3/14).
Agency.  Noma Construction and Development was the operating entity that ordinarily signed these kind of joint check agreements (10/23).
Agency.  The Joint Check Agreement "appears to be" signed by Mr. Toma's secretary, Sherry (9/24).
Assent.  Bob has no way of knowing if Phase II meant the 2nd cul de sac (12/16).
Assent.  Bob never saw the Joint Check Agreement before (5/14).
Consideration.  Bob doesn't remember if Plaintiff's equipment went into Defendant's project (11/23).
Entity,  Bob is the president of four corporations:  Noma Group, Noma Properties, Noma Management, and Noma Construction and Development (1/19).

i.               Using a 3-column Table to Sort Keywords in Word 2007.  This doesn’t take special software.  You can use a 3-column table in Word or you can just put the keyword as the first word in a paragraph and then sort the paragraphs alphabetically.






Then, highlight the table and in Word 2007 click Layout




Then click A-->Z Sort