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Deposition Summary With Page and Line
River digests the transcript into propositions, each carrying its page and line, and puts every answer the errata sheet changed next to the original.
A digest is only worth the citations in it. River reads the transcript and returns the testimony as propositions organised by topic, each one carrying the page and line range it came from, so a fact goes into a brief with its cite already attached. Exhibits are tied to the pages where they were marked and to the answers given about them. Nothing is paraphrased past the point where the underlying words stop supporting it.
Then it does the two things a template cannot. Where an errata sheet has come back, the digest row carries both answers and the reason the witness gave for the change, because the original does not leave the record when the correction arrives. And every contradiction is filed by what it can actually do at trial. Some come in for their truth and some only damage the witness, and the difference is where the earlier statement was made rather than how badly it conflicts.
The designation worksheet comes out of the same read. Each passage you plan to play carries the surrounding question and answer that fairness pulls in with it, so the counter-designation is visible before the other side serves it rather than a week later. This is the same discipline as proving each privilege claim to its elements, and it rests on exhibits whose Bates ranges actually resolve, which is what validating a production before it loads is for.
The transcript keeps both answers
An errata sheet does not overwrite anything. On request made before the deposition ends, the rule gives the deponent thirty days to review the transcript once the officer reports it is available. Where there are changes in form or substance, the deponent signs a statement listing the changes and the reasons for making them. The officer then notes the review in the certificate and attaches whatever came back. Both versions sit in the record, and the reason column is where the argument happens.
A contradiction is not one thing. A prior inconsistent statement is not hearsay, and so is evidence of the fact itself, only where it was given under penalty of perjury at a trial, hearing, or other proceeding or in a deposition. The rule names places. A declaration signed at a desk is an unsworn declaration under penalty of perjury by the statute's own title, and it is not one of them. So the same conflict proves a fact against one source and only dents credibility against the other.
Two more rules decide what the index has to record. Extrinsic evidence of a prior inconsistent statement waits until the witness has had an opportunity to explain or deny it, so whether counsel put the document to the witness on the record is a column rather than a footnote. And a designated passage drags in other parts that in fairness should be considered, which is why each designation carries its span. Evidence offered solely for impeachment is outside the pretrial disclosure, so the two sheets are deliberately separate.
How it works
Hand over the transcript
The transcript in any format, the errata sheet if one came back, and prior statements.
Testimony gets read
Every page, with the page and line range recorded against each proposition as it is written.
Conflicts get sorted
Each contradiction is filed by what it can do and whether the witness was confronted.
Designations come back
The passages you would play, each with the span fairness brings with it and the objection risk.
What you get
- Every proposition carries the page and line range the words actually came from
- Errata changes shown against the original answer, with the reason the witness gave
- Contradictions filed by what they prove, not just by how sharp they look
- A confronted-on-the-record column, because extrinsic evidence needs the witness given that chance
- Designations paired with the surrounding passage that fairness pulls in alongside them
- Exhibits tied to the page they were marked and the answers given about them
Common questions
What transcript formats does it read?
PDF, ASCII, condensed, PTX and RTF, with the page and line numbering read from the transcript itself rather than reconstructed. Hand it the certified final rather than the rough. A rough draft is paginated differently, so a cite taken from one and checked against the other lands somewhere else entirely.
What happens if the errata sheet arrives after I run it?
Run it again with the errata attached and the digest reconciles itself. Every row the changes touch is reissued carrying both versions and the reason given, and the rows they do not touch stay as they were. The reason column is the part worth reading, because a change with a thin reason is itself worth examining.
Does it decide what is admissible?
It sorts, and you rule. Each contradiction arrives with where the earlier statement was made, whether the witness was confronted on the record, and which of those two facts is doing the work. That is the material an evidentiary argument is built from, laid out so the attorney makes the call in seconds rather than reconstructing it.
Can it handle several depositions in one matter?
Yes, and that is where the index earns its keep. Contradictions across witnesses are found the same way as contradictions inside one transcript, and they land next to the dated events the production established. Two operations managers giving different accounts of the same night is the finding a per-transcript summary structurally cannot produce. An expert's transcript reads against the opinions numbered before the examination.
What about the exhibits marked at the deposition?
Each one is tied to the page where it was marked and to every answer given about it, so an exhibit and its testimony travel together. Where those exhibits came out of a production, their Bates ranges have to resolve, which is what checking a load file before it ingests settles first.
Why is the designation sheet separate from the impeachment index?
Because the rules treat them differently. Pretrial disclosure covers what you intend to present other than solely for impeachment, so designations go on a list the other side gets and objects to on a clock, and impeachment material does not. Mixing them hands over the cross before you run it.
Where does the digest go next?
Into the motion, the cross outline and the designation list, all keyed to the same cites. Where the dispute turns on a contractual deadline, the digest sits alongside the register that computes when notice was actually due, so the testimony about when somebody was told is measured against the clause rather than against a recollection.
Deposition Summary With Page and Line
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