Workflow template for legal and contracts
Deposition transcript summary
Before the next deposition, a motion or trial, the attorney has a draft page-line summary of the transcript, arranged by the topics they named: every point cited, every exhibit and objection logged, and every place the testimony differs flagged without a label. The attorney decides what it means.
This workflow template prepares legal work for a lawyer to review. It gives no legal advice and has not been reviewed by a lawyer. A lawyer decides and signs.
Add it to a workflow in the Fully Powered Planner, beside the teams and roles that will run it. Book a fit call
The outcome
The attorney sits down to prepare with the witness's whole testimony already sorted under the topics that matter to the case. Every point carries its page and lines, so any point can be found in the transcript straight away. Where the witness gave two different times, a date that differs from a document, or an answer the errata sheet changes, both places are quoted together, each with its cite. Every objection is logged with what followed it, every exhibit with where it was marked, and a follow-up list shows what the record says is still outstanding: documents named in testimony that are not exhibits and were not supplied, things the witness offered to provide, questions left unanswered. The first read is prepared for the paralegal to check and the attorney to review, and the attorney's time goes to the judgment only a lawyer can make.
What it does not do. It gives no legal advice. It decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines. It sends, files, signs and calendars nothing. It quotes and locates; it never characterises. Nothing is called an admission or evasive, and the summary never says which of two passages is right. An instruction not to answer is recorded, never assessed. It writes no cross-examination questions, no brief section, no letter and no filing, even for the attorney to edit. It names no case, statute or rule from memory. If one reaches it, whether the attorney gave it, someone passed it on, or it is cited in the transcript or a document, it is shown only in the words it came in, flagged for the lawyer to verify, and never described as current, valid or good law. Asked whether the draft is ready to sign, what testimony means, when something is due, what a claim is worth or what to do, it says only that this is for the named attorney and points to the line of the draft concerned. Everything it prepares is a draft for the named attorney.
Who starts the work, and when
A paralegal or associate starts it when the transcript arrives with its page and line numbers, once the attorney has named the topics to read it for. The attorney who will use it, usually the handling attorney preparing for the next deposition, a motion or trial, reviews it. In a company with no lawyer of its own, the summary is prepared for the outside counsel on the case and goes to that counsel, never to the business as an answer.
It is not for notes of a meeting or an interview that was not under oath: meeting agenda, notes and follow-ups and customer interview synthesis do that work.
What they supply
- The transcript, every page, with the cover, appearances, index and reporter's certificate, with every page and line number still on it.
- The attorney's request: the matter, the case number, the witness, the attorney's name and the topics, in the attorney's order.
- The errata sheet, if the witness made one.
- Documents to compare with, such as the exhibits, each with a Bates number or page number.
- Other transcripts to compare with, if the attorney wants them, with their page and line numbers.
The workflow template compares the testimony with nothing else: nothing remembered, nothing from the internet, nothing from another matter.
What comes out
One draft, headed for the named attorney to review, in a fixed order:
- Proceeding: court, caption, date, counsel, reporter and how the deposition ended, each with its cite.
- Testimony by topic: each question in plain words with the witness's answer quoted, its page and lines, and a neutral flag where it differs from another place, such as "Differs from p. 6, ll. 7–8".
- Differences: each one with both places quoted and cited and the fact they concern, including every change on the errata sheet.
- Objections: each with its words, the question and what followed: answered, withdrawn, rephrased or no answer.
- Exhibits: each with its description, Bates range, where it was marked and whether the index agrees.
- Follow-up list: what the record shows is outstanding, with the passages, and no recommendation.
- Transcript condition: pages read, anything missing or unreadable, reporter's markers, and whether the copy is certified.
- Attorney to confirm: a line for the topics, each difference, the objections, the exhibits, the follow-up list, the transcript's condition and the cite check.
If a page is missing or the copy is a rough draft, the draft says so at the top in capitals. If the transcript has no page and line numbers, or no topics were given, nothing is prepared until they are.
An invented example
Illustrative example with invented data. Ferrand Quill LLP, Selwick Danner LLP, Orrin Valley Produce Co., Kestrelmark Cold Storage, Inc., every person named, the Superior Court of Valdemere, the case, the transcript, the errata sheet and the two documents below are all invented. Nothing here describes a real case, court or person.
The paralegal's five inputs come first, in full, then what the workflow template prepares.
Input 1: the request
Sent by Imogen Bray, paralegal, on Tuesday 10 November 2026.
Teodor wants a summary of the Lunde transcript before Dale Pruett's
deposition on 19 November. The certified copy is in the matter file.
Nothing in it is marked confidential.
Matter: Orrin Valley Produce Co. v. Kestrelmark Cold Storage, Inc.,
case no. TB-CV-26-00417. We act for the plaintiff.
Witness: Gareth Lunde, deposed 22 October 2026.
For: Teodor Vasko, handling attorney.
Topics, in Teodor's order:
1. The alarm and the timeline of the night of 13 to 14 March
2. Maintenance and condition of unit 3
3. Notice to Orrin Valley
Compare with: Exhibit 1 (KCS-000112 to KCS-000113), Exhibit 2
(KCS-000140) and the errata sheet. No other transcripts yet.
Input 2: the transcript
Page 1
1 SUPERIOR COURT OF VALDEMERE
2 COUNTY OF TOLLBROOK
3
4 ORRIN VALLEY PRODUCE CO., )
5 Plaintiff, )
6 v. ) Case No. TB-CV-26-00417
7 KESTRELMARK COLD STORAGE, INC., )
8 Defendant. )
9
10
11 DEPOSITION OF GARETH LUNDE
12
13 Thursday, October 22, 2026
14 10:04 a.m.
15
16 Taken at: Ferrand Quill LLP, 400 Harbour Row,
17 Suite 9, Tollbrook, Valdemere
18
19
20
21
22 Reported by: Ines Marchetti, Certified Court
23 Reporter No. 5521
24
25
Page 2
1 APPEARANCES
2
3 For the Plaintiff, Orrin Valley Produce Co.:
4 TEODOR VASKO
5 Ferrand Quill LLP
6 400 Harbour Row, Suite 9, Tollbrook, Valdemere
7
8 For the Defendant, Kestrelmark Cold Storage, Inc.:
9 RUTH ADEYEMI-CROSS
10 Selwick Danner LLP
11 12 Mill Lane, Tollbrook, Valdemere
12
13 Also present: Priya Holm, Kestrelmark Cold Storage, Inc.
14
15
16
17
18
19
20
21
22
23
24
25
Page 3
1 INDEX
2
3 WITNESS PAGE
4 GARETH LUNDE
5 Examination by Mr. Vasko 4
6
7
8 EXHIBITS
9
10 NUMBER DESCRIPTION MARKED
11 Exhibit 1 Unit maintenance log, KCS-000112 5
12 to KCS-000113
13 Exhibit 2 Email of March 14, 2026, KCS-000140 6
14
15
16 REQUESTS ON THE RECORD PAGE LINE
17 Sensor download, chambers C and D 7 8
18
19
20
21
22
23
24
25
Page 4
1 GARETH LUNDE,
2 having been first duly sworn, testified as follows:
3
4 EXAMINATION
5 BY MR. VASKO:
6 Q. Good morning. Please state your name and your
7 position.
8 A. Gareth Lunde. I'm the warehouse operations
9 manager at the Kestrelmark site on Quarry Road.
10 Q. How long have you held that position?
11 A. Since May 2023.
12 Q. I'd like to talk about the night of March 13 into
13 March 14 of this year. Were you on site?
14 A. No. I was called at home.
15 Q. What time did the temperature alarm for chamber C
16 go off?
17 A. Around 2 a.m., I'd say.
18 Q. Who called you?
19 A. Dale Pruett, the night supervisor.
20 Q. What did Mr. Pruett tell you?
21 A. That chamber C was reading eleven degrees and
22 climbing, and that unit 3 had stopped.
23 Q. What is unit 3?
24 A. It's the compressor that serves chambers C and D.
25 Q. What did you do after the call?
Page 5
1 A. I drove in. I got there maybe forty minutes later.
2 Q. When was unit 3 last serviced before that night?
3 A. In February, I think the second week.
4 Q. Who serviced it?
5 A. Our outside refrigeration contractor.
6 Q. I'm handing you what's been marked as Exhibit 1.
7 (Exhibit 1 marked for identification.)
8 Q. Do you recognize it?
9 A. It's our unit maintenance log.
10 Q. It bears the numbers KCS-000112 through 113. Is it
11 kept in the ordinary course?
12 MS. ADEYEMI-CROSS: Objection. Form.
13 A. We keep it at the front desk. Whoever does the
14 work signs it.
15 Q. Please look at the entry for unit 3. What date
16 does it show for the last service?
17 A. It says January 2. That's what's written.
18 Q. Was unit 3 serviced again after January 2?
19 A. I'd have to check the work orders. I can get those.
20 Q. Had anyone raised concerns about unit 3 before
21 March?
22 MS. ADEYEMI-CROSS: Objection. Calls for
23 speculation.
24 MR. VASKO: Only if you know.
25 A. Dale mentioned it was cycling a lot in February.
Page 6
1 Q. Did you report that to anyone?
2 A. No. I didn't think it was a problem.
3 Q. Let's go back to the alarm. When you got there,
4 what did you do?
5 A. We moved what we could from C into D, but D runs
6 off the same unit, so that didn't hold for long.
7 Q. What time did the alarm first sound that night?
8 A. The alarm, that would've been after four.
9 Q. Did you call Orrin Valley that morning?
10 A. No, I didn't call them.
11 Q. Did anyone at Kestrelmark contact Orrin Valley?
12 A. I emailed them around eight.
13 Q. I'm handing you Exhibit 2.
14 (Exhibit 2 marked for identification.)
15 Q. Is this the email you sent?
16 A. Yes.
17 Q. The time on it is 6:52 a.m. Do you see that?
18 A. I see that.
19 Q. Before you sent it, did you speak with anyone about
20 what to say in it?
21 A. I spoke with Priya and with our counsel's office.
22 Q. What did counsel's office tell you?
23 MS. ADEYEMI-CROSS: Objection. Privileged. I'm
24 instructing the witness not to answer.
25 Q. Will you follow that instruction?
Page 7
1 A. Yes.
2 Q. Did you keep any record of the chamber temperatures
3 that night?
4 A. The sensor system logs it. There's a download you
5 can pull from the panel.
6 Q. Has that download been pulled?
7 A. I believe Priya pulled it, yes.
8 MR. VASKO: We'd ask that the sensor download for
9 chambers C and D for March 13 and 14 be produced.
10 MS. ADEYEMI-CROSS: We'll take it under
11 advisement.
12 Q. Who else was on shift that night besides
13 Mr. Pruett?
14 A. Two loaders, I think. I'd have to look at the
15 [inaudible] roster.
16 Q. Mr. Lunde, what caused unit 3 to stop?
17 MS. ADEYEMI-CROSS: Objection. Form. Foundation.
18 Q. Do you know what caused unit 3 to stop?
19 A. I don't know. The contractor wrote a report.
20 Q. Have you seen that report?
21 A. No.
22 MR. VASKO: That's all I have for today. We'll
23 keep the deposition open for the sensor download.
24 (Deposition adjourned at 11:12 a.m.)
25
Page 8
1 REPORTER'S CERTIFICATE
2
3 I, Ines Marchetti, Certified Court Reporter No. 5521,
4 certify that the witness was sworn, that the foregoing
5 pages 1 through 8 are a true record of the testimony
6 given, and that the witness was given the opportunity to
7 read and sign the transcript.
8
9 Dated: October 29, 2026
10
11 [signed]
12 Ines Marchetti
13
14
15
16
17
18
19
20
21
22
23
24
25
Input 3: the errata sheet
ERRATA SHEET
Deposition of Gareth Lunde, October 22, 2026
Case No. TB-CV-26-00417
PAGE LINE NOW READS SHOULD READ REASON
6 10 "No, I didn't call them." "No, I didn't call them Clarification.
before I emailed."
Signed: Gareth Lunde Date: November 5, 2026
Input 4: Exhibit 1, the unit maintenance log
KESTRELMARK COLD STORAGE · QUARRY ROAD · UNIT MAINTENANCE LOG
DATE UNIT WORK SIGNED
04 Nov 2025 1 Filter change D. Pruett
19 Nov 2025 3 Refrigerant top-up contractor
02 Jan 2026 3 Compressor service contractor
15 Jan 2026 2 Belt replaced D. Pruett
KCS-000112
DATE UNIT WORK SIGNED
03 Feb 2026 1 Door seal repaired D. Pruett
21 Feb 2026 4 Compressor service contractor
KCS-000113
Input 5: Exhibit 2, the email
From: Gareth Lunde
To: Orrin Valley Produce Co., receiving desk
Sent: Saturday, March 14, 2026 6:52 AM
Subject: Chamber C temperature event
Chamber C lost cooling overnight after unit 3 stopped. Your pallets in
C and D are affected. We are checking the stock and will send an update
today.
Gareth
KCS-000140
What the workflow template prepares
DRAFT DEPOSITION SUMMARY · FOR TEODOR VASKO TO REVIEW
Prepared for Teodor Vasko's review. It gives no legal advice. It decides
nothing about legal meaning, merit, validity, privilege, conflicts or
deadlines. It sends, files, signs and calendars nothing: nothing has been
sent, filed, signed or calendared. It labels no testimony.
Matter: Orrin Valley Produce Co. v. Kestrelmark Cold Storage, Inc.
Case no.: TB-CV-26-00417
Witness: Gareth Lunde, deposed Thursday, October 22, 2026 (p. 1, ll. 11–13)
Prepared for: Teodor Vasko, who reviews and decides
Topics, in the attorney's order: 1. The alarm and the timeline of the night
of 13 to 14 March; 2. Maintenance and condition of unit 3; 3. Notice to
Orrin Valley
PROCEEDING
- Court and caption: Superior Court of Valdemere, County of Tollbrook;
Orrin Valley Produce Co., Plaintiff, v. Kestrelmark Cold Storage, Inc.,
Defendant; Case No. TB-CV-26-00417 (p. 1, ll. 1–8)
- Date, time and place: Thursday, October 22, 2026, 10:04 a.m., Ferrand
Quill LLP, 400 Harbour Row, Suite 9, Tollbrook, Valdemere
(p. 1, ll. 13–17)
- Examined by: Mr. Vasko (p. 4, l. 5)
- Appearances: Teodor Vasko, Ferrand Quill LLP, for the plaintiff, Orrin
Valley Produce Co.; Ruth Adeyemi-Cross, Selwick Danner LLP, for the
defendant, Kestrelmark Cold Storage, Inc. (p. 2, ll. 3–11)
- Also present: Priya Holm, Kestrelmark Cold Storage, Inc. (p. 2, l. 13)
- Court reporter: Ines Marchetti, Certified Court Reporter No. 5521
(p. 1, ll. 22–23)
- Ended: "(Deposition adjourned at 11:12 a.m.)" (p. 7, l. 24)
- Errata sheet: supplied, signed November 5, 2026, 1 change
TESTIMONY BY TOPIC
1. The alarm and the timeline of the night of 13 to 14 March
1.1 Whether he was on site on the night of March 13 into March 14.
Answer: "No. I was called at home." (p. 4, ll. 12–14).
1.2 What time the temperature alarm for chamber C went off. Answer:
"Around 2 a.m., I'd say." (p. 4, ll. 15–17). Differs from p. 6,
ll. 7–8 (D1).
1.3 Who called him. Answer: "Dale Pruett, the night supervisor."
(p. 4, ll. 18–19).
1.4 What Mr. Pruett told him. Answer: "That chamber C was reading eleven
degrees and climbing, and that unit 3 had stopped." (p. 4, ll. 20–22).
1.5 What he did after the call. Answer: "I drove in. I got there maybe
forty minutes later." (p. 4, l. 25 to p. 5, l. 1).
1.6 What he did when he got there. Answer: "We moved what we could from
C into D, but D runs off the same unit, so that didn't hold for long."
(p. 6, ll. 3–6).
1.7 What time the alarm first sounded that night. Answer: "The alarm,
that would've been after four." (p. 6, ll. 7–8). Differs from p. 4,
ll. 15–17 (D1).
1.8 Whether he kept any record of the chamber temperatures that night.
Answer: "The sensor system logs it. There's a download you can pull
from the panel." (p. 7, ll. 2–5).
1.9 Whether that download has been pulled. Answer: "I believe Priya
pulled it, yes." (p. 7, ll. 6–7).
1.10 Who else was on shift that night besides Mr. Pruett. Answer: "Two
loaders, I think. I'd have to look at the [inaudible] roster."
(p. 7, ll. 12–15).
2. Maintenance and condition of unit 3
2.1 What unit 3 is. Answer: "It's the compressor that serves chambers C
and D." (p. 4, ll. 23–24).
2.2 When unit 3 was last serviced before that night. Answer: "In
February, I think the second week." (p. 5, ll. 2–3). Differs from
KCS-000112 (D2).
2.3 Who serviced it. Answer: "Our outside refrigeration contractor."
(p. 5, ll. 4–5).
2.4 Handed Exhibit 1, whether he recognizes it. Answer: "It's our unit
maintenance log." (p. 5, ll. 6–9).
2.5 Whether the log, numbered KCS-000112 through 113, is kept in the
ordinary course (O1). Answer: "We keep it at the front desk. Whoever
does the work signs it." (p. 5, ll. 10–14).
2.6 What date the log shows for the last service of unit 3. Answer: "It
says January 2. That's what's written." (p. 5, ll. 15–17).
2.7 Whether unit 3 was serviced again after January 2. Answer: "I'd have
to check the work orders. I can get those." (p. 5, ll. 18–19).
2.8 Whether anyone raised concerns about unit 3 before March (O2).
Answer: "Dale mentioned it was cycling a lot in February."
(p. 5, ll. 20–25).
2.9 Whether he reported that to anyone. Answer: "No. I didn't think it
was a problem." (p. 6, ll. 1–2).
2.10 What caused unit 3 to stop, asked again as whether he knows what
caused it (O4). Answer: "I don't know. The contractor wrote a
report." (p. 7, ll. 16–19).
2.11 Whether he has seen that report. Answer: "No." (p. 7, ll. 20–21).
- See 1.4.
3. Notice to Orrin Valley
3.1 Whether he called Orrin Valley that morning. Answer: "No, I didn't
call them." (p. 6, ll. 9–10). Changed by errata (D3).
3.2 Whether anyone at Kestrelmark contacted Orrin Valley. Answer: "I
emailed them around eight." (p. 6, ll. 11–12). Differs from
KCS-000140 (D4).
3.3 Handed Exhibit 2, whether it is the email he sent. Answer: "Yes."
(p. 6, ll. 13–16).
3.4 Whether he sees the time on it, 6:52 a.m. Answer: "I see that."
(p. 6, ll. 17–18).
3.5 Whether, before sending it, he spoke with anyone about what to say
in it. Answer: "I spoke with Priya and with our counsel's office."
(p. 6, ll. 19–21).
3.6 What counsel's office told him (O3). No answer: see O3.
(p. 6, ll. 22–24).
3.7 Whether he will follow that instruction. Answer: "Yes." (p. 6, l. 25
to p. 7, l. 1).
4. Other testimony
4.1 His name and position. Answer: "Gareth Lunde. I'm the warehouse
operations manager at the Kestrelmark site on Quarry Road."
(p. 4, ll. 6–9).
4.2 How long he has held that position. Answer: "Since May 2023."
(p. 4, ll. 10–11).
DIFFERENCES
D1. Differs from p. 6, ll. 7–8
Here: "Around 2 a.m., I'd say." (p. 4, ll. 15–17)
There: "The alarm, that would've been after four." (p. 6, ll. 7–8)
Same fact: the time the alarm went off on the night of March 13 into
March 14
D2. Differs from KCS-000112
Here: "In February, I think the second week." (p. 5, ll. 2–3)
There: "02 Jan 2026 3 Compressor service contractor"
(KCS-000112)
Same fact: the date of the last service of unit 3 before that night
(KCS-000113 lists no entry for unit 3)
D3. Changed by errata
Here: "No, I didn't call them." (p. 6, ll. 9–10)
There: "No, I didn't call them before I emailed." (errata sheet, entry
for p. 6, l. 10; reason given: "Clarification.")
Same fact: whether he called Orrin Valley that morning
D4. Differs from KCS-000140
Here: "I emailed them around eight." (p. 6, ll. 11–12)
There: "Sent: Saturday, March 14, 2026 6:52 AM" (KCS-000140)
Same fact: the time his email to Orrin Valley was sent
OBJECTIONS
O1. p. 5, l. 12. By Ms. Adeyemi-Cross. "Objection. Form."
Question: "It bears the numbers KCS-000112 through 113. Is it kept in
the ordinary course?" (p. 5, ll. 10–11)
Followed by: Answered, p. 5, ll. 13–14.
O2. p. 5, ll. 22–23. By Ms. Adeyemi-Cross. "Objection. Calls for
speculation."
Question: "Had anyone raised concerns about unit 3 before March?"
(p. 5, ll. 20–21)
Followed by: Answered, p. 5, l. 25. Said in between: "Only if you
know." (Mr. Vasko, p. 5, l. 24)
O3. p. 6, ll. 23–24. By Ms. Adeyemi-Cross. "Objection. Privileged. I'm
instructing the witness not to answer."
Question: "What did counsel's office tell you?" (p. 6, l. 22)
Followed by: Instruction not to answer stated, p. 6, ll. 23–24; no
answer.
O4. p. 7, l. 17. By Ms. Adeyemi-Cross. "Objection. Form. Foundation."
Question: "Mr. Lunde, what caused unit 3 to stop?" (p. 7, l. 16)
Followed by: Question rephrased, p. 7, l. 18, then answered, p. 7,
l. 19.
EXHIBITS
E1. Exhibit 1: "Unit maintenance log, KCS-000112 to KCS-000113" (index,
p. 3, ll. 11–12). Bates: KCS-000112 to KCS-000113.
Marked: p. 5, l. 7. Referred to: p. 5, ll. 6–17.
Among the documents supplied: yes.
Index: gives p. 5; marked there.
E2. Exhibit 2: "Email of March 14, 2026, KCS-000140" (index, p. 3,
l. 13). Bates: KCS-000140.
Marked: p. 6, l. 14. Referred to: p. 6, ll. 13–21.
Among the documents supplied: yes.
Index: gives p. 6; marked there.
FOLLOW-UP LIST
What the record shows. Whether anything is done about any item is for
Teodor Vasko.
F1. "the work orders".
Not an exhibit and not supplied
Offered by the witness: "I'd have to check the work orders. I can get
those." (p. 5, l. 19)
F2. What counsel's office told him.
Not a document
Question not answered: "What did counsel's office tell you?" (p. 6,
l. 22); instruction not to answer, O3
F3. "the sensor download for chambers C and D for March 13 and 14".
Not an exhibit and not supplied
Named in testimony: "… There's a download you can pull from the
panel." (p. 7, ll. 4–5)
Named in testimony: "I believe Priya pulled it, yes." (p. 7, l. 7)
Requested on the record: "We'd ask that the sensor download for
chambers C and D for March 13 and 14 be produced." (p. 7, ll. 8–9)
Reply on the record: "We'll take it under advisement." (p. 7,
ll. 10–11)
Kept open on the record: "… We'll keep the deposition open for the
sensor download." (p. 7, ll. 22–23)
F4. "the [inaudible] roster".
Not an exhibit and not supplied
Named in testimony: "… I'd have to look at the [inaudible] roster."
(p. 7, ll. 14–15)
F5. "a report" by the contractor.
Not an exhibit and not supplied
Named in testimony: "… The contractor wrote a report." (p. 7, l. 19)
Named in testimony: "Have you seen that report?" "No." (p. 7,
ll. 20–21)
TRANSCRIPT CONDITION
- Pages read: 8 of 8 (reporter's certificate, "pages 1 through 8",
p. 8, ll. 3–5)
- Missing or unreadable: none
- Reporter's markers: [inaudible] at p. 7, l. 15
- Numbering: continuous, pages 1 to 8, lines 1 to 25 on every page
- Copy: certified (p. 8, ll. 1–12)
- Designations: none marked
ATTORNEY TO CONFIRM
[ ] Topics 1 to 3: the points under each are the testimony you need. ____
[ ] D1. The time the alarm went off. Whether this is a difference, and
what it means, is yours. ____
[ ] D2. The date of the last service of unit 3. Whether this is a
difference, and what it means, is yours. ____
[ ] D3. Whether he called Orrin Valley that morning. Whether this is a
difference, and what it means, is yours. ____
[ ] D4. The time his email was sent. Whether this is a difference, and
what it means, is yours. ____
[ ] Objections O1 to O4: what followed each is as the transcript shows. ____
[ ] Exhibits E1 to E2: the list is complete. ____
[ ] Follow-up items F1 to F5: what to do about each is yours. ____
[ ] Transcript condition: [inaudible] at p. 7, l. 15. ____
[ ] Cites checked against the transcript by Imogen Bray. ____
CHECK
- Points: 30 (topic 1: 10; topic 2: 11; topic 3: 7; Other testimony: 2).
"See" lines are not counted.
- Differences: 4 (1 within the transcript, 1 from the errata sheet,
2 from documents, 0 from other transcripts).
- Objections: 4. Exhibits: 2. Follow-up items: 5.
- Compared with: KCS-000112 to KCS-000113 (Exhibit 1); KCS-000140
(Exhibit 2); the errata sheet. Other transcripts: none supplied.
- Not used for comparison: none.
- Written to these rules, for Imogen Bray to check against the
transcript: every question put to the witness in a point; every point,
difference, objection, exhibit and follow-up item with the page and
lines where it was read; no testimony labelled; nothing said about what
anything means in law.
Reviewed by Teodor Vasko: ____________ Date: ________
This is a draft for Teodor Vasko. The review line records the attorney's
review. What the testimony means, and how it is used, are the attorney's.
Three things to notice. The alarm time (D1) and the email time (D4) are each shown with both places quoted and cited, and the summary does not say which is right or why they differ. The instruction not to answer (O3) is recorded with what followed it, and F2 carries its number, with nothing about privilege. The follow-up list says what the record shows about the sensor download, the work orders, the roster and the contractor's report; whether to ask for any of them, and what to put to Dale Pruett on 19 November, is Teodor Vasko's decision.
Imogen Bray checks the cites against the transcript and gives the draft to Teodor Vasko. Where it goes after that, if anywhere, is his decision.
Where it fits
- Legal and contracts: the legal team owns the transcript, the topics and every decision about the testimony.
- Law firms, in litigation groups where depositions come in faster than anyone can read them twice, and a summary has to be right to the line.
- Insurance, where claims and coverage disputes produce transcript after transcript and in-house counsel works with outside counsel on each.
- Construction, where a delay or defect dispute means many site witnesses, many documents and testimony that has to be set against the logs.
- Established businesses, where a long-running dispute builds a record too large for one person to hold in their head.
It sits beside court-order deadline notice preparation in a litigation team's week, and weekly open-matter check is where an outstanding follow-up item gets its owner.
What has to change for your company
The topics are the attorney's, and they are the heart of this. Many teams keep a standing list for each kind of case, which the attorney edits for each witness. Choose your cite style once, add the words your attorneys never want to see in a summary, decide who checks the cites and how many, and say where the draft is kept in the matter file. The attorney confirms that the firm's policy and any protective order allow transcripts and exhibits to be used in the AI product you have approved.
We sit with the paralegal who prepares the summaries and the attorney who uses them, on transcripts they already know well, and set it up in ChatGPT, Claude, Copilot or Gemini. Your firm keeps control of how the work gets done.
What has been checked
Fully Powered AI wrote this workflow template, drawing on a published page-line summary method credited in its sources. It was editorially reviewed on 11 November 2026 and had three independent reviews that day, with changes after each; the second failed it on a wrong file path in its source credits, which was corrected. It was tried on its invented example in Claude the same day, with pressure tests that asked for advice and planted an invented citation and an instruction in the inputs; the record of every run and change is published with it. A separate review of the legal boundary then found the summary's heading shorter than the rule requires and the replies to the pressure tests saying more than they should; the instructions were tightened, and the five pressure tests were run again by the session that made the changes, which is not an independent run. Only the first run was made without sight of the example's output. It has not been reviewed by a lawyer. It has not yet been tested in a client environment. It has not yet been tested as a packaged version in ChatGPT, Claude, Copilot or Gemini.
Testing in your firm means running it on two or three past transcripts whose summaries your attorneys already trust, plus hard cases written in advance: two different answers to the same question, an errata sheet that changes an answer, an instruction not to answer, a missing page, and a request to say whether testimony is an admission. The paralegal checks the cites against the transcript before the summary goes to the attorney. Pilot acceptance-test preparation builds that test set, and what we test before we call an AI workflow ready describes the record we keep.
Who decides
Your people keep
- What the testimony means
- Which topics matter to the case
- Which of two passages is right
- What to do about the follow-up list
It does not
- Gives no legal advice
- Decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines
- Sends, files, signs and calendars nothing
- Never characterises testimony
- Writes no cross-examination questions, brief section, letter or filing
- Names no case, statute or rule from memory
Questions people ask
Who is it for?
A paralegal or associate starts it, and the attorney who will use it, usually the handling attorney preparing for the next deposition, a motion or trial, reviews it.
What do I need to supply?
The transcript, every page with its page and line numbers, the attorney's request with the topics in the attorney's order, the errata sheet if there is one, and any documents or other transcripts to compare with.
What does it not do?
It gives no legal advice and decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines. It quotes and locates and never characterises; the named attorney decides and signs.
What do I get?
One draft for the named attorney: the testimony by topic with page and line cites, the differences, the objections, the exhibits, a follow-up list and the condition of the transcript.
What has been checked?
It was editorially reviewed and tried on its invented example in Claude on 11 November 2026. It has not been reviewed by a lawyer, and it has not yet been tested in a client environment.
The full workflow template
Everything above is the outline. The complete workflow template is the working version: the roles, the inputs, the procedure, the exceptions and stop conditions, the output format, the reviewer checklist, the acceptance tests, the instructions for an AI assistant and what to customize for your company. It comes with a download and the link to its folder in Fully Powered’s public repository.
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Next step
Put this workflow template to work for your team: on your plan, or built with you in a sprint.
Build this in a sprint
In a sprint, Fully Powered adapts this workflow template to your rules, proves it on your own work and puts it in the hands of the roles that own it.
Two ways to begin: