Deposition summary

A deposition is 200 to 400 pages of questions and answers in the order a lawyer asked them, not in the order a reader needs them. The summary reorganizes it by topic, keeps the page and line for every statement, and quotes the witness's own words where the words matter. The database beside it holds every answer as one row with its topic, so that a later question ("what did anyone say about the alarm log?") is a search, not a re-read.

Two uses, two readers. Counsel reads the summary before the next deposition, the motion, or trial preparation. Claude reads the database when the deposition-compare skill or the case-brief skill asks what this witness said. Both need the same thing: accuracy to the line.

1. Inputs

• The transcript: PDF or text, with page and line numbers. Confirm the numbering survives extraction (pdftotext -layout keeps the line numbers in the left margin; check five pages at random). If the transcript is a scan, OCR it and mark the summary OCR; verify quotations against the certified copy.
• The errata sheet, when it exists; apply it to the rows it changes and flag each changed row.
• The exhibits marked at the deposition, with their exhibit numbers and, when the matter has one, their document IDs or Bates numbers from the case-brief archive.
• The matter context (from the case brief when it exists): the device, the event date, the parties, the witness's role and employer, and the topics the team cares about. Without it, the topics come from the transcript alone, and the summary says so.

2. Read the transcript once, in order, into rows

Work through the transcript from the first page to the last. Do not skip the preliminaries (they hold the witness's background and the stipulations) or the end (it holds the errata and the exhibit list).

Write testimony.csv, one row per question-and-answer unit (a question and its answer, or a short run of questions on one point):

row · page · line start · line end · examiner (by role: plaintiff's counsel, defense counsel, co-defendant) · topic · subtopic · question (gist) · answer (gist) · verbatim (the witness's exact words when they matter: an admission, a number, a date, a name, a denial, a qualification) · exhibit · document ref · date mentioned · person mentioned · device element (component, software version, alarm, log, setting) · answer type · flag · note

Rules for the rows: - Gist is a short, neutral restatement. It never adds what the witness did not say. - Verbatim is exact, including "um", false starts, and the question when the answer only makes sense with it. Ellipses only for omitted material, never to change meaning. - Answer type, one code: fact · estimate · opinion · admission · denial · don't know · don't recall · objection-no answer · instructed not to answer · reads document · corrects earlier answer. - Flag, when applicable: contradicts [row n] (the witness said something different earlier), contradicts [D-0042 p.7] (a document says otherwise; cite it), confirms [D-0042 p.7], errata-changed, hearsay, speculation (witness says so), key. - A long answer that covers two topics becomes two rows with the same page and lines. - The topic list is fixed before the pass starts (section 3) and grows only when the transcript forces it; write the final list, with one-line definitions, to topics.md.

Keep a query-log.csv for any search you run against the archive while flagging contradictions.

3. Topics

Start from this list, and from the matter's own topics in the case brief, and delete what the witness never reached:

• Background: education, employment, role at the time, role now, reporting line, prior testimony
• The device: what it is, versions, the witness's involvement in its design, manufacture, service, use, or purchase
• The event: what the witness saw, heard, did, or was told; when; who was present
• Before the event: training, procedures, maintenance, prior problems, prior complaints, warnings
• After the event: reports, investigations, device custody, repairs, resets, communications
• Records: logs, service records, complaint files, emails, the exhibits shown
• Design and risk (for manufacturer witnesses): requirements, risk file, testing, changes, known issues, decisions
• Field (for manufacturer witnesses): complaints, MDR decisions, CAPAs, field actions, trend reviews
• Clinical use (for hospital witnesses): setup, alarms, settings, staffing, response
• Opinions and expectations: what the witness believes caused the event, what they would have expected
• Foundation and limits: what the witness does not know, was not involved in, or cannot recall

4. Verify before you write

• Open twenty rows at random against the transcript page; every page, line, and verbatim quotation must match. If any fails, check the whole file, not the twenty.
• Every contradicts [D-…] flag: open the document page and confirm it says what the flag claims.
• Every admission row: read the question again. An answer of "yes" to a compound or leading question is fact or estimate with the question in verbatim, not an admission, unless the witness adopted the statement in their own words.
• Errata: every row the errata changes carries errata-changed and both versions in note.

5. Write the summary

summary.md, four to eight pages for a full-day deposition:

1. Header: witness, role and employer at the time and now, date, examining counsel, length (pages), exhibits marked, errata (yes / no / pending), transcript source and whether it is certified.
2. In one paragraph: who the witness is to the matter and the five to ten statements that matter most, each cited [112:4–113:2].
3. By topic, in the order of section 3: for each topic, a short paragraph or list of what the witness said, with page:line after every statement and the verbatim words for the key ones. Mark admissions, denials, and "don't know / don't recall" answers as such.
4. Documents shown: a table — exhibit number, document ref, what it is, what the witness said about it (recognized / did not recognize / authored / received / disputed), page:line.
5. Conflicts: a table — the statement, the earlier statement or the document it conflicts with, both citations, and the nature of the difference. State the difference; do not characterize it.
6. What the witness could not or did not say: the don't know, don't recall, instructed not to answer, and objection-no answer rows grouped by topic, with page:line. This section is read before the next deposition.
7. Not asked: topics in the list that an examiner never reached, and questions the answers invite. Written as questions, so they can go into the next outline.
8. Sources: transcript file, errata, exhibits, the archive index date.

Beside it: testimony.csv, topics.md, exhibits.csv (exhibit no. · document ref · title · pages shown · rows), query-log.csv.

Citation form: [Depo Lastname 112:4–113:2] in anything that leaves the summary; [112:4–113:2] inside it.

6. The database

testimony.csv is the database. For a matter with several witnesses, each summary's CSV goes into one folder, depositions/, with the witness name in the file name, and one depositions/index.csv (witness · role · date · pages · rows · topics covered · summary file). The deposition-compare skill reads that folder. Keep the columns identical across witnesses; a search that works on one must work on all.

7. Rules

• Page and line on everything. A statement without a cite is deleted, not kept.
• The witness's words, not a paraphrase, wherever the words carry weight.
• Gist adds nothing; verbatim changes nothing.
• "Admission" is a narrow word; use it narrowly.
• No assessment of credibility, demeanor, or truthfulness. The summary shows what was said, what the documents say, and where they differ. Counsel judges the witness.
• Errata applied and flagged, never silently.