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Deposition summaries services at Zeta Intelex are provided by staff who understand that delivering high-value deposition summaries requires both litigation expertise as well as strong English writing skills. Attorneys drafting these types of summaries are experts at reviewing, analyzing, identifying most salient facts, and producing a well articulated synopsis.

Our customers come back to us again and again. We are particular, deal with technical subject matter like auto accident, medical malpractice an personal injury, and our staff are trained to pick up nuggets of gold from vast tracts of information.

Sample Deposition Summary Medical Malpractice


Trial Transcript Summary of witness
___________V. _________

EXAMINATION BY_____________________

15:22, 16:12-22, 17:01-22, 18:01-08, 18:19-22, 19:1-17, Patient’s last knee revision surgery, performed by Dr. Petrera was unnecessary The witness asserted that the patient had a painful knee after a knee replacement surgery performed by the witness. Dr. Petrera made some bad decisions regarding the sizes of components and joint level and as to what was causing the patient pain and carried out a revision surgery. However, 3-5% of patients who had knee replacement surgery developed a painful knee, sometimes stiff, sometimes not. No matter how perfectly performed, knee replacement surgery did not work for a certain percentage of patients. Further, the witness was experienced enough, having performed 2000 orthopedic surgeries, to judge the correct size of components. Even after the revision performed by Dr. Petrera, the patient did not get complete relief. Had the witness used wrong sized components, the patient would have received complete relief after the revision surgery, where these components were changed. Dr. Petrera was therefore wrong in concluding that the witness had used disproportionately big components during the original knee replacement, which caused the patient pain. Some patients developed scars after knee replacement surgeries; this was the cause of the patient’s pain. The surgery was also unnecessary because the patient was improving. It was less than a year from the previous knee replacement carried out by the witness. Patients of knee replacement surgeries were known to get better over a year from their surgery. It was prudent to wait further before concluding whether a revision was necessary.
20:12-22, 21:1-22 The patient was within the category of 3-5% patient who got a bad result from knee replacement surgery The witness was trained to judge correct sizes of components. Therefore, wrong sized components did not cause the patient’s pain. Further the patient suffered from pain after the original knee surgery, and continued to suffer after the revision surgery performed by Dr. Petrera. It was true that sometimes the first revision did not work, and a third surgery was performed. However, for patients who fit into the 3-5% category, even a 100 surgeries would not work.
22:11-17 A proper Tibial Insert was used by the witness, the joint line was proper The witness asserted the tibial insert was proper, as was the joint line.
23:01-22, 24:01-05 Releasing the scar tissue would have been better than a revision The witness estimated that the patient left his treatment 3 months after her surgery. The witness would have waited at least 3 more months, and rather than performing a revision, had the pain persisted, he would have looked into the patient’s knee with an arthroscope and release the scar tissue. This outpatient lysis of adhesions would have been a more benign outpatient surgery than the revision, with quicker recovery and no blood loss. The witness was an expert in performing this lysis procedure, and had performed an estimated 50 such procedures. He was often asked to speak on the subject.
24:10-22, 25:01-02 The Popliteus Tendon could have been left unreleased during the surgery Medical practitioners followed different procedures as to the Popliteus Tendon. Some surgeons released it during each surgery, to prevent any risk of snapping. The witness however, preferred to leave it intact during knee replacement surgery and released it only if it snapped, either during or after surgery.
25-09-22, 26-01-15 The joint line after the surgery by the witness was the same as the joint line before The witness used a setting of zero while making a femoral cut. He compared the pre and post operative  x rays and confirmed that the joint line was in the same place.