Testimony taken in depositions often plays an important part in building your legal case. The Federal Rules of Civil Procedure and state rules give deponents the right to read and make corrections to the deposition transcript. If that right is asserted during the deposition itself, the deponent has a set time period (as specified in the applicable rules) from the time they are notified that a transcript of the deposition is available to exercise that right.
There are several reasons to routinely review the deposition transcript before trial:
- Correct Mistakes. The right to make changes to deposition testimony allows the deponent to identify and correct any transcription errors before the trial. Court reporters are human; even the most diligent transcriptionist may make an occasional error. If a word was mistyped or omitted, the apparent meaning of a deponent’s answer could change dramatically. Reviewing the transcript allows for correcting typos and other errors.
- Make Substantive Changes. Deponents can also make substantive changes to their deposition testimony during the transcript review process. However, they should know that any substantive changes will be scrutinized closely, and the original testimony will be provided along with the change and the deponent’s reasoning for making the change.
- Help Structure Attorney’s Case. Reviewing deposition transcripts also provides attorneys with the opportunity to parse the testimony for useful information. This can help attorneys build their trial strategies by identifying passages they want to use during trial, pre-trial discovery, pre-trial memoranda, etc.
- Give Experts Time to Prepare. Experts appreciate having as much time as possible to review deposition transcripts because it can help them analyze the information and prepare their testimony.
- Review and Summarize. Deposition transcripts are often voluminous and can be hundreds of pages. Preparing deposition summaries well in advance of trial can help you locate key information and exhibits quickly and easily when you need them.
Baer Reed’s expert litigation support attorneys offer deposition summaries customized to provide concise overviews of key information captured during deposition testimony. To learn more, contact us online or call 888-433-1990 today.









Mr. Reyes graduated with honors from the Ateneo de Manila University, where he received the Procter and Gamble Student Excellence Award. He obtained his Juris Doctor degree from the Ateneo de Manila School of Law. During law school, Mr. Reyes was part of the Philippine delegation to the Willem C. Vis International Commercial Arbitration Moot held in Vienna, Austria. He was also a member of the Ateneo Society of International Law and the St. Thomas More Debate Society. He completed his internship at the Public Attorney’s Office. He wrote a thesis entitled: “To Kill A White Elephant: An Analysis of the Fiduciary Exception to the Corporate Attorney-Client Privilege”. Mr. Reyes is admitted to practice law in the Philippines and the State of New York.
Matthew Hersh earned a B.A. in Political Science from Columbia University in 1990 and graduated cum laude from Georgetown University Law Center in 1999. He also holds a master’s degree in international relations from the Georgetown University School of Foreign Service.
Cap. Avi Levak (Res. IDF) graduated from from Israel’s prestigious Ben-Gurion University of the Negev with a Bachelor of Science in Computer Science and Mathematics. He is also a Leadership and Communication coach trained in TuT coaching by Alon gal in Israel. Avi specializes in high-level, in-depth analysis of business and client needs, within systems and software strategy and architecture.
Ms. Lardizabal-Manzano is a graduate of San Sebastian College-Recoletos, where she earned her B.A. in Political Science. In 2003, she received her law degree from Lyceum of the Philippines and was admitted to practice law in 2004.
Mr. De Guzman graduated from San Beda College with a degree of Bachelor of Arts Major in Economics and received his law degree from San Beda College of Law. He is multilingual and is fluent in three languages: Chinese, Filipino, and English. He was admitted to the Philippine Bar in 2003.
Ms. Aquino-Batallones obtained a Bachelor of Arts degree in Development Studies (with Minors in Global Politics and Hispanic Studies) from the Ateneo de Manila University. In 2011, she received her Juris Doctor degree from Ateneo de Manila University School of Law. During law school, she interned at Romulo Mabanta Buenaventura Sayoc & de los Angeles then became an intern of Ateneo Legal Services Center’s Clinical Legal Education Program.
Ms. Cruz-Anonuevo graduated cum laude and top nine in her batch from Miriam College with a degree of Bachelor of Arts in InternationalStudies. She obtained her Juris Doctor degree from Ateneo de Manila University School of Law in Rockwell. During law school, she interned in Rivera, Santos, Maranan & Associates. She was also part of Ateneo’s Labor Law Bar Operations. She wrote her thesis on, “Stealing Privacy: Limitations on Media’s Photographic Invasion.,” Ms. Cruz-Anonuevo is admitted to practice law in the Philippines.
Ms. Tyler graduated cum laude from Georgetown University and received her law degree, cum laude, from Georgetown University Law Center. During law school, she interned at the United Nations Economic Commission for Europe. She also worked on The Tax Lawyer journal and was a member of the award-winning Barristers’ Council Mock Trial Team. Ms. Tyler is admitted to practice law in the State of California and the District of Columbia.