Create a Consolidated Deposition Exhibit

If you are deposing a witness who, for example, was the principal respondent to a number of interrogatories, it is helpful to have all of the relevant questions and answers in one exhibit for marking and handling. Here is a PDF approach to doing that.

First, gather the relevant text — in this example, interrogatories and responses — into a single text document. In my practice, we routinely get discovery responses in electronic form (usually MS Word) so there’s not a lot of re-typing required. Copy and paste the relevant text into a new text document. Make sure you preserve the numbering of the original questions and answers (beware of Word trying to ‘help’ you with automatic numbering).

Mining for all of the responses can get complicated quickly when there are multiple sets of interrogatories, responses, and amended responses. Therefore, I prefer to start each new question/answer on a new page. To do this in Word, you place your cursor on the line below the last paragraph of the response and hit Ctrl + Enter for a hard page break. This will make your life easier if you need to add or delete questions, since this allows you to move stuff around a page or more at a time.

Once you are sure you have all of the relevant text in your word processing document, create your Exhibit PDF. Why bother? Why not just leave it in Word? You certainly can do so if you are just going to print it at your office. However, the last time I did this exercise I was on the road, and not sure what the printer situation was going to be. I ended up at Kinko’s (which is 100% PDF-friendly), but if I had to print at someone else’s office, I like to be able to hand them a disk and know that the file will print, even though I created the document in, say, Nisus Writer Classic for Mac. In addition, with a PDF you can use some very cool collaborative commenting features for creating deposition questions. I like to make pretty much everything into PDF for storage, indexing, searching, and case management purposes.

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About the Author: David Fishel

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