Deposition Summaries

Summarize Depositions Using Facts & Issues


Depositions are traditionally summarized in an unstructured way using MS Word and containing explanatory text in paragraph form. There are numerous disadvantages and inefficiencies with this method. There are no assigned date ranges, issues or persons that may be filtered and sorted. Searches are not possible across multiple deposition summaries. Traditional summaries also lack links to transcript language, text and exhibits, requiring manual cross-referencing of the summary with the supporting documents. Utilizing Facts & Issues in LEP for your deposition summaries creates structured, organized work product with greater efficiency due to automation of many processes that were traditionally time-intensive, manual actions.

Creating Deposition Summaries with Facts and Issues

The steps below outline how to review, analyze and log data that will create an effective deposition summary collection. The process begins with uploading deposition transcripts and exhibits. The transcript is then read and reviewed in the Doc Viewer. Summary facts and text are pulled from the transcript and entered as fact titles. Additional information for each fact, such as date information and contested status, is then added for increased organization and reference. After review is complete and all the data is available in the Facts and Issues section, facts and other fields may be filtered, searched and sorted. Issues for the case may also be created in this section and facts assigned to each issue. Colleagues may then filter and review digested deposition analysis in the Facts & Issues section. An Excel log and supporting documents may be downloaded as a deposition summary document and/or binder.

Step 1-Upload Deposition Transcripts and Exhibits

Add Deponent Name to Custodian List

Add the deponent name as a Custodian prior to uploading your transcript and exhibits. See the Custodians help page for directions on adding a deponent name to the case. Use last name, first name formatting and add title, role, affiliation and other information related to the deponent.

Upload Transcript and Exhibits to LEP

Before adding transcripts and deposition exhibits, it is best practice to rename them using a consistent file naming convention that will sequentially line up transcripts and deposition exhibits when viewed in Facts & Issues page or when exporting Excel logs and Briefcases.

For example:


2018-01-07 Smith John Transcript 000


2018-01-07 Smith John Transcript 001 Exhibit

2018-01-07 Smith John Transcript 002 Exhibit

2018-01-07 Smith John Transcript 003 Exhibit

See Add Case Documents for directions on uploading documents to LEP as an Upload Batch. Select the deponent name for the Custodian field in the Upload Batch window:

LEP supports transcripts in PDF and TEXT format. Proprietary formats will require conversion to PDF or TXT format. Please load single page PDF versions rather than versions containing multiple pages condensed on one page.

Upon upload, the transcript and exhibits will have their text extracted and OCR performed. This action makes all the text searchable, even if the original files were non-searchable scans.

Step 2-Add Doc Type Coding to Transcripts and Exhibits

Adding Doc Type coding to your uploaded documents for “Transcript” and “Transcript Exhibits” allows for quick filtering to these specific documents based on Deponent.

Select Case>Add Case Documents and select the Upload Batch containing the transcript and transcript exhibits for review. This brings up the transcript and exhibits in the Browse screen.

Select the deposition transcript and select Multi Doc Edit from the left operation column.

Select “Doc Type” from the Multi Doc Edit drop-down menu.

Type “Transcript in the textbox and select Update.

Repeat this operation by selecting all exhibits from the Browse screen and adding “Transcript Exhibit” to the Doc Type textbox and Update.

Step 3-Add Filter Quick Link for Deposition Transcript and Exhibits

With this coding complete, along with the Deponent/Custodian coding completed during the upload, the user can create and share a Filter Quick Link to quickly bring up a deposition and exhibit set.

In the Browse view, expand Filters and click Select Filters.

Scroll to Custodian and select your deponent name.

Additionally, scroll to Doc Type and select both Transcript and Transcript Exhibit.

Select APPLY and the Browse view will bring up the deposition and corresponding exhibits.

Expand Filter Quick Links from the left operation column and select Edit.

Rename the most recent Filter, select the Share icon and select OK.

This Filter will now be listed under Shared and all users will be able to view and use this Quick Filter to bring up these documents quickly. This coding combined with the initial file naming convention will line up the deposition collection in order:

Step 4-Review Transcript in Doc Viewer and Add Facts

Open transcript in the Doc Viewer

Select PAGE or PDF view.

Select the Facts Tab.

Add Deposition Summary Facts

As the reviewer moves through the transcript, create a new fact for each substantive summary point identified. Add the substance of the fact and/or transcript text directly to the Title field. You may copy text directly from the PDF view of the transcript and paste in the Title text box. Both the PDF view and Page view contain searchable images so it is easy to highlight and copy text. Adding corresponding data to each field will help increase the organization and reference capability of the deposition summary.

Date Start and End: The Start field indicates the start date for a fact and the End field refers to the end date. If the fact occurs on a single date, enter that date in both the Start and End columns.

Contested: The Contested field allows the user to indicate whether a fact is contested or uncontested and if contested, by whom.

Material: The Material field indicates whether a fact is material, not material, or undecided.

Doc/Page: Allows the user to associate a fact to a specific page of the deposition.

Title: Copy/paste transcript text. Enter the substance of the text and/or the fact in the Title field. Facts are easier to work with when the Title refers to one fact rather than several facts or a compound fact.

Assign Custodians to Fact: This field allows the user to associate one or more deponents with a deposition fact. Select the Deponent name from the dropdown list.

Assign Facts to Issues: This allows the user to associate facts with one or more Issues of the case.

Step 5-Highlight Transcripts and Create Annotated Versions of Transcripts (Optional)

LEP provides a feature called the Annotation Editor in the Doc Viewer screen, which allows the user to highlight transcript text and add brief notes to the transcript using up to five different highlight colors. Once LEP creates the annotated version of the document, a user will have the option to view the annotated document from the Annotated tab in the Doc Viewer. The clean, original version of the transcript will always be available from the other tabs (PDF, Page, HTML, Original).

With the transcript open in the Doc Viewer, select the DOC tab, expand Annotation and choose Open Annotation Editor.

LEP will generate an Annotation image, make sure to refresh the page until the transcript image appears.

To highlight text, click and drag to box out a text highlight.

The Edit Annotation box will open, delete the annotation text, select the highlight color, and select Save Annotation.

To create a "Post-It" type note, drag a box over whitespace on the image and type in desired notes in the annotation text, select the note color and save the annotation.

The annotated transcript may be printed as needed or saved as a PDF for attaching to motions. The multiple highlight color capability allows this tool to be useful for creating deposition designations in addition to the summary.

Step 6-Add Issues

Once review is complete and all facts identified and coded, you may review all Facts & Issues for the deposition under Analysis>Facts & Issues.

Add Issues to the case under Issues>Create New Issue.

Facts may be assigned to one or multiple issues in the case. A list of issues will appear in the upper right-hand corner of the Facts & Issues view and are hyperlinked to their associated facts.

The Facts & Issues feature allows the reviewer to select the fields they wish to view and filter the deposition facts by these fields. Select Show Columns to add or remove fields in your view, including dates, contested status, transcripts, and deposition exhibit links through including the Docs field.

The Filters option uses the coding options selected during the transcript review and fact creation. The collection may be filtered by fact, contested status, materiality, document (transcript or exhibits) and custodian/deponent. For example, to quickly find all material facts from James Shelton's deposition contested by opposing counsel, simply filter to Custodian = Shelton, James, Material Facts = Yes and Contested = Yes, by Them.

Step 7-Perform Keyword Searches

Select Keyword Search to run search terms across all fact text added to the Title field, including any copied transcript language. Search results may then be filtered down by the available fields such as custodian/deponent and contested status. With traditional MS Word deposition summaries, it would not be possible to search across multiple deposition summaries. By using Facts & Issues, search terms may be quickly applied across all deposition digests, providing another valuable analytical tool to case preparation.

Step 8-Export Deposition Fact Summary Log

Use the export feature to create and share an Excel log of your extracted facts and corresponding fields, including hyperlinks to the Facts in LEP. First, use the Show Columns feature to select all fields to include in the summary log. Then select all facts to export in the grid view. Once all the facts are selected, choose Export>Export to Excel.

Step 9-Export to Briefcase

Use the Briefcase export feature to export all documents assigned to the facts including transcripts and exhibits. Export and print out the corresponding deposition summary fact log along with the supporting transcript and exhibits to easily create a deposition digest hard copy binder or e-binder. A Briefcase will also have a web download link that you may share with colleagues. A LEP user account is not needed to download a Briefcase from a shared link.

Select all facts to export in the grid view. Once all facts are selected, choose Export>Export to Briefcase. Add a title and comments, check the share box to generate a link and select how the files should be named. Once processing is complete, download the briefcase from the tab Case>Download Briefcase.

The downloaded zip file will contain ORIGINAL and normalized PDF images of the transcript and exhibits.

Additional Resources

Facts & Issues Help Note

Working With Transcripts and Exhibits


Additional Assistance

For questions or additional assistance, please contact Lexbe’s Professional Services department at