ThomasMoreAI Deposition Summary with Key Document Index
Transforms a deposition transcript into a topic-based summary table with integrated exhibit cross-references for rapid navigation between testimony and documentary evidence.
Prerequisites
- Complete deposition transcript with page and line numbering
- Exhibit list and files referenced or marked during deposition
- Case context: party names, key contract sections, claims at issue
Workflow
1. Review Transcript
Read the full transcript and identify:
- Natural topic breaks (explicit subject changes and thematic shifts)
- Every exhibit reference — formal ("Exhibit 3") and informal ("the email we just reviewed")
- Key admissions, contradictions, evasive answers, and authentication testimony
2. Extract Topics
For each topic, capture:
| Element | Requirement |
|---|---|
| Topic heading | Specific — "Witness Knowledge of Payment Default Under §4.2" not "Payment Issues" |
| Page:line range | Start and end of testimony on that topic |
| Summary | 2-3 sentences, neutral, no legal conclusions |
| Exhibits referenced | Exhibit number + how witness characterized/authenticated it |
| Notable moments | Admissions, contradictions, refusals to answer |
3. Build Exhibit Index
Create a master exhibit cross-reference table:
| Exhibit | Description | Transcript Refs (pg:ln) | Witness Characterization |
|---|---|---|---|
| Ex. 1 | [doc type] | 45:3-47:12, 102:8-103:1 | [how witness described it] |
4. Assemble Summary Table
Primary deliverable — two-column table:
| Transcript Cite | Topic & Summary |
|-----------------|-----------------|
| pp. 12:4-18:22 | **Formation of the Supply Agreement**
| | [2-3 sentence neutral summary]. See Ex. 3
| | (Supply Agreement, discussed at 14:8-15:2).
| | Notable: Witness admitted not reading §4.2
| | before signing (15:18-22). |
Within each summary cell:
- Embed exhibit references discussed during that testimony
- Cite specific page:line for key admissions
- Use hierarchical headings for major topics vs. subtopics
5. Output
Produce both:
- DOCX — formatted table with hyperlinks to exhibits and transcript locations
- PDF — preserved hyperlinks, full-text searchable, locked for filing
Key Rules
- Neutral tone only — summarize what the witness said, not what it means for the case
- Specificity over brevity — "Witness denied receiving the October 14 demand letter" not "Witness denied receiving correspondence"
- Organize by substance, not questioner — consolidate redirect and direct testimony on the same topic under one heading
- Capture authentication testimony — note when witness identifies, authenticates, or disputes a document
- Flag evasive responses — mark non-responsive answers, memory claims, and qualified answers
Quality Checklist
- Every exhibit mentioned in testimony appears in summary and exhibit index
- No exhibits referenced that weren't actually discussed
- All page:line citations verified against transcript
- Summaries reflect actual testimony — no interpretation or legal conclusions
- Topic headings specific enough for at-a-glance navigation
- No privileged communications or work product included
- Hyperlinks resolve to correct targets