Deposition Preparation

Within Storybuilder, your Deposition Prep space is collaborative amongst your team and integrates with your Evidence and Facts. You can use a Deposition as a one-stop-shop for deposition prep: outline and draft questions on your own or with the Everlaw AI Writing Assistant, chat with your teammates, and link to potential exhibits without leaving your Deposition.

During a deposition, you can use the Prep space to tag exhibits and timestamp key moments. 

The Summary space gives you a clean slate to write up your notes during and after a deposition.

Read this article to learn about the tools available within the Deposition Prep and Summary.

There is more to learn about Depositions:

• For an introduction to creating a Deposition and an overview of all the Deposition tools, see our Introduction to Depositions article
• To read tips and best practices during a Deposition, see our Conducting a Deposition article
• To learn about exhibits and how to export them, see our Exhibits in Depositions and Drafts article
• To learn about working with a transcript after a deposition is completed, see our Work with a Deposition Transcript article

Requirements

To access a Deposition, you must meet one of the following:

• Be the creator
• Have Admin permission for Storybuilder
• Have the Deposition shared with you. You can have one of the following permission  levels:
  • View: View the Deposition, but make no edits
  • Edit: View and edit the Deposition. If a user also has Edit or Full Access permission on the Story, they can add evidence to the Deposition that isn't already on the Evidence page.
  • Full access: View, edit, share, and delete the deposition. If a user also has Edit or Full Access permission on the Story, they can add evidence that isn't already on the Evidence page.

Writing Assistant

Writing Assistant is one of the generative AI tools built into Storybuilder. It's built to help you synthesize, structure, and brainstorm using your evidence. To learn how to use Writing Assistant, see our Writing Assistant article.

Word processing tools (Body and Summary)

The Prep Body and Summary are word processing spaces, with tools to format your text. 

You can:

• Import a DOCX file
• Add headings 
• Choose your font size and styling
• Highlight text
• Create numbered and bulleted lists
• Adjust the indent and alignment of text 
• Insert tables
• View History

These tools mirror those available in Drafts. To learn more about word processing tools, see our Drafts article.

Evidence panel

When you're working on a Deposition, you can integrate evidence (documents, document highlights, and testimony from completed depositions) into your preparation using the Evidence panel. Evidence that you add here can be referenced within your drafting and to create and export exhibits.

The integration of your key evidence directly within your preparation space lets you complete all your prep without toggling between different tools to keep track of your outline, team communications, and evidence. When you upload a transcript, referenced exhibits in the transcript text can link directly to previews of your evidence.

Evidence added to the Evidence panel displays all its Story details (labels, description, etc.), which simplifies your prep and supports your team in building a coherent and consistent narrative.

You can add evidence to the Evidence panel in several ways. This gives your team flexibility to prepare in whatever way works for you. Outside the Deposition, you can add evidence in several ways:

• The review window: Add documents and document highlights into a Deposition
• The results table, via a batch action: Add documents into a Deposition
• Your Evidence page, using the Deposition label: Add documents, document highlights, and testimony in to a Deposition
• From the transcript of a completed deposition: Add testimony into a Deposition

To learn the details of how to add documents and document highlights into your Story and into a specific Deposition, see our Add Evidence to your Story article.

Add evidence within the Deposition

While you're working in your Deposition, You can add evidence two ways:

• Type or paste the Bates/Control# of the document directly into your Deposition body. When you do so, the Bates number turns into a document reference and the document is added to the Evidence panel.
  See the autoconvert section for details on how to switch the auto-link feature on and off.

  Tip

  You can paste an entire list of Bates/Control # into the Body to add them into your Evidence panel all at once. This is useful if someone has shared a list of Bates/Control # with you outside of Everlaw and you want to add them to the Deposition all at once.

• Select + Add Evidence at the bottom of the Evidence panel. This opens a list of the documents already added to the Evidence page for you to select from.
  Optionally, enter the Bates/Control # of a document that isn't listed and select ADD TO STORY. This adds it to your Evidence panel and to the Story (Evidence page).
  . 

To learn more about adding excerpts of a transcript as evidence to your Deposition, see our Work with a Deposition Transcript article.

To learn more about working with exhibit lists, see our Exhibits in Depositions and Drafts article.

Add testimony within the Deposition

When you type or paste a citation for deposition testimony (from an uploaded transcript) into the Prep section, it creates a link directly to the relevant section of the transcript.

Once a link is created, you can use it to open  the transcript in a new tab, where the cited lines are selected.

From here, you can add the citation as a highlight or take other actions described in our Work with a Deposition Transcript article.

To add testimony within a deposition:

1. Type the citation for any transcript already uploaded to Everlaw in the following format:
   [Testimony citation] [page number]:[line number range separated with a hyphen]

   Note

   Testimony citation is not necessary if you are citing from the transcript within the Deposition you are typing in.

2. Enter a space or select "Enter" on your keyboard. If Everlaw detects that this is a citation, it will automatically create a link after you enter a space. 
   If the cited text has already been added to the Story as Testimony, the Testimony is added to the Deposition's evidence panel (if it's not already there) and is displayed as an expandable "chip" that contains the cited text.

The screenshot below is taken from the Prep section of the Lee Deposition and shows how citations link:

• The citation "8:4-16" links to testimony on lines 4-16 on the 8th page of the Lee transcript (within the same Deposition)
• "Carter 6:5-8" links to testimony on the transcript in the Carter Deposition
• "Carter 6:5-12:14" links to testimony spanning pages 6-12 in the Carter Deposition
• The expanded transcript excerpt is displayed because "Carter 18:13-20" has already been highlighted and added as Testimony to the Story

The Testimony citation to type is the one designated when the transcript was uploaded. To find the citation for a given Deposition:

1. Go to the Deposition Transcript page.
2. Select the Settings button, then Edit citation. 
   
   The text within the Testimony citation field is the citation to use.
   

To learn more about adding excerpts of a transcript as evidence to your Deposition, see our Work with a Deposition Transcript article.

To learn more about working with exhibit lists, see our Exhibits in Depositions and Drafts article.

Sort and filter evidence

Once evidence is added to the panel, documents and document highlights are listed in the Documents section and testimony is listed in the Testimony section.

Within these sections, you can sort by date, Bates/Control#, or name. To choose a sort order, select Bates (asc) to open a menu listing other sort options. Then, select the one you want.

You can also filter the evidence. To do so, select All to open a menu of options for what to view. Then, select what you want to view.

In the Documents section, you can filter based on whether or not the evidence:

• Is used (referenced in the body of your Deposition)
• Has been marked as an exhibit
• Has a name

In the Testimony section, you can filter based on whether or not the testimony is used (referenced in the body of your Deposition).

For both evidence types, you can type into the filter bar to filter for specific evidence:

• For documents: Filter by Bates number or Story title
• For testimony: Filter by Deposition citation.

Reference evidence

Once a piece of evidence is in the Evidence panel, it can be added as a reference into your Deposition body.

To reference evidence in your Deposition body, select the  Add to body button next to the document or testimony to add it to the body of your Deposition. This adds the evidence wherever your cursor is.

To add the evidence to a specific location in the body, drag and drop it to the spot you want within the body. 

Documents and testimony in the document panel that are referenced in the body are white, while those that are not referenced are gray. 

Once a piece of testimony or a document text highlight is referenced, use the caret button to reveal the full text quote.

The expanded form has additional functionality:

• Use the copy button  to copy the text and its citation, which you can paste outside of Everlaw. The pasted text includes the full text quote, followed by the citation in parentheses. 
• For testimony, use the View deposition button to jump to the testimony within its source Deposition.
• For document highlights made with the text selector, select the Preview button to open a preview of the document. 

Add page-level bookmarks

Drafting using evidence often requires granular citations to connect specific, relevant aspects of the evidence to the argument or analysis. To support this, you can add bookmarks to specific pages of a document. There are three ways to do this: 

• By typing the specific page number into the Deposition body
• By selecting the bookmark button while viewing a specific page in the document preview
• By adding specific page numbers to the Bookmarks section of the document details 

Add a page bookmark via Bates number

1. Make sure you're in the Deposition body.
2. There are two ways to cite a specific page. Either:
   • Type the Begin Bates/Control # of the multi-page document you want to cite, followed by a period (.). Helper text appears, prompting you to add a page number.
     Then, type the page number you want to cite.
     
     This will also add the document to your Evidence panel, if it wasn't there already
   • Type the Bates number of the specific page you want to cite. For example if Document ABC10 is 15 pages and you want to cite the second page, type ABC11.
3. Hit Enter or Space on your keyboard. This links the document and creates a bookmark of the page you entered.

Add a bookmark in the document preview

If you are scrolling a preview of a multi-page document and note a particularly relevant page, you can add a bookmark to that page. To do so, either select the Bookmark page button on the top right corner of the page, or select the Add bookmark to this reference button on the preview's side panel. In both instances, this adds a bookmark to the page.

Add a bookmark from the Evidence panel

If you already know the page you want to bookmark, you can add it without previewing the document: 

1. Select the document reference within the body to expand its details.
   
2. Select the plus button located under BOOKMARKS ON THIS REFERENCE.
   
3. Type the page number in the input box.
4. Select the correct Bates number / page from the list provided.

Using bookmarks

Once your page is bookmarked, you can quickly jump to the important page. There are two ways to open a document preview to a bookmarked page:

• Double click its reference in the Deposition body. This will open the document preview to the first bookmarked page (if there are more than one). Use the Bookmarks on this reference to jump to later bookmarked pages.
• If you know you want to open the document to a later bookmark, select the document citation in the Deposition to open the details of the document in the Evidence panel. Then, select the page you want to open to in the Bookmarks on this reference section
  

Mark exhibits

Once a document is identified as an exhibit during a deposition, you can mark it with a corresponding exhibit number within Storybuilder. This is useful for linking exhibits within the completed deposition transcript and for exporting exhibits with their appropriate numbers.

To mark a document as an exhibit:

1. Select the document in the Evidence panel in the list to open the document details view. From there, you can assign an exhibit name, which consists of the prefix and the alphanumeric identifier. This is also commonly referred to as the exhibit number.
   
2. If the exhibit is identified with a prefix other than "Exhibit" within the transcript text, such as its Bates prefix, enter that prefix in the Prefix field.
3. Enter the Exhibit number of the document. For example, if a document is referred to as "Exhibit 1", its exhibit number is "1". If it is referred to as "ABC 073," its exhibit number is "073" (and its prefix is ABC).
4. Select Save.

Facts

Facts from your Fact timeline(s) likely have lots of important and useful information: people who were involved, relevant Evidence, and details about how the Fact relates to the case overall. When you're preparing for a Deposition, it can be useful to pull that information together without having to rewrite it. To do so, you can add Facts into the Facts panel and then reference them in the body of your Deposition.

To add a Fact to a Deposition:

1. Open the Deposition or Draft.
2. In the side panel, select Facts to open the Facts tab.
   
3. At the bottom of the tab, select + Add Facts.
   
   This opens the Add Facts dialog.
4. Using the checkboxes, select the Fact(s) you want to add.
   
5. When ready, select Review.
6. Review your selection.Then select Add.
   
   This closes the dialog. The Fact(s) are added to the Fact list in the side panel.

Use Facts 

To add a Fact to the body of your Deposition or Draft, select its plus button, or drag and drop it into the text editor.

Select the caret button to display the Fact's description.

Any Evidence that is associated with a Fact referenced in your Deposition body is displayed in the Exhibits view, and can be exported as part of an exhibit list. To learn more about exhibit lists, see our Exhibits in Depositions and Drafts article article. 

Timer

The Deposition timer is useful for time tracking during your deposition. In particular, you can timestamp chat communications as well as any written notes in your Deposition text body. This allows you to flag and later recall critical moments of the deposition.

Read more about using the timer in Conducting a Deposition.

Chat

The chat panel can be used to communicate with one another during preparation and throughout a deposition. This is useful for time-sensitive matters, such as which exhibits to introduce next, or communicating with others from your team who are not physically present at the deposition. 

To send a chat, select the input box, type your chat, then press Enter. Anyone with any access to the Deposition can read, write, and export chat messages. 

Here are some additional details about chats:

• Unread messages are indicated by a notification badge in the Chat panel.
  If you are on a different panel, you will see “User says…” on your deposition panel.
• Messages that are received while the chat is open and the user has scrolled to the bottom automatically marked as read
• If the timer is running, any chat you send will be time stamped automatically. To send a chat without a timestamp, click the timestamp in the input box and delete it.
• You can hyperlink documents automatically within Chat. To do so, type in an exact Bates number. The number will turn blue to indicate a linked document.
  
• If you select a document reference in the chat, it automatically opens in a new Quick Review window
• To export the chat transcript and timestamps to a TXT file, select the caret button on the Chat panel, then select Download chat transcript
  

Tasks

Before, during, or after a deposition, you can create and assign tasks for yourself and others. A task includes a description, a checkbox to indicate completion, an assignee, and a due date. 

Required permissions: Users must have Edit permissions on the Deposition to have full task permissions. 

Organization Admins who are not on the project can view and edit all tasks, but cannot assign themselves to a task.

Users with  View permissions on the Deposition, you can view all tasks but can only complete those assigned to them. These users cannot edit the tasks themselves or create new tasks. 

All users with any access to the Deposition can sort, filter, and show/hide completed tasks. 

Create, edit, and complete a task

To create a task, type into the text bar of the Task panel and press Enter on your keyboard. 

By default, tasks you create are assigned to you and will not include a due date.

To rename a task:

1. Select the task description.
2. Type in the new task description.
3. Press Enter. 

To assign a task due date, select No due date, which opens the date picker. 

Choose the date and, optionally, a time. Select out of the date picker to close it. Due dates are displayed in the local time zone. If the task was created with a due date of 3:00 PM in California, it will be displayed as 6:00 PM for a user who views the task in New York.

To clear the due date, select the date and then Clear on the top right of the dialog box. 

Overdue tasks are indicated by red text.

To complete a task, select the box next to it. If your completed tasks are hidden, they will disappear from view. Otherwise, the description will receive a strikethrough. 

To delete a task, select its due date (or (No due date))  to open the date picker, Then, select Delete task.

Assign tasks

To re-assign a task to another person, select the user profile bubble. This opens a list of users who have access to the Deposition. Then, choose the user you want to assign the tasks to from the drop-down menu. 

To unassign a task, select Clear on the top right of the reassignment dialog.

Task display

To filter or sort your tasks, select the caret at the top of the Tasks tab. By default, tasks are sorted by earliest due date to latest due date.  You can sort by:

• Due date
• Date added
• Who the task is assigned to

By default, all tasks are displayed. You can filter your tasks by: 

• Tasks created by you
• Tasks assigned to you

To hide completed tasks, select Hide completed tasks on the bottom of the Tasks panel. 

Any changes you make to the view of the Tasks panel are specific to you.

Export

For offline work, you can export the Deposition to a Word document or PDF. When you export a PDF, you also have the option to include the images of any documents you have referenced in the deposition body. The references are linked to their place within the exported PDF. This lets you see your outline/questions and jump to any potential exhibits referenced within it, without leaving the PDF.

To export your Deposition:

1. From the deposition body, select Export.
   
2. Choose your format. All formats include the content of your Deposition body and links to reference testimony and documents. Links to testimony take you to the transcript in Everlaw. For referenced documents: 
   1. PDF: Referenced document links take you to view the document in Everlaw
   2. PDF (with images): Referenced document links take you to the document exported within the PDF 
   3. Word document: Referenced document links take you to view the document in Everlaw
3. The export starts. When it's done, it is available to download on the Homepage from the Batches & Exports column for 28 days.

Summary

The Summary is a separate word processing space that you can use during or after a deposition. It lets you capture notes and followup thoughts without creating a separate document or object to navigate to. 

Since the Summary space is intended for notes based on work in the Prep space, there is no Evidence panel, meaning that you cannot directly link to documents or testimony. Consequently:

• You cannot export a PDF with images
• Writing Assistant generations do not link to evidence citations as they do when inserted into the Prep space

The Summary is not included when you use the Deposition as a template for creating a new one.

Deposition Settings

Word Count

Word count is turned on by default in all Depositions. To turn it off, select Settings and switch off Word count.

Here are some additional details about word count:

• Anyone with access to a Deposition can see the word count
• URLs are counted as one word
• Bates/Control # are counted as one word
• Document citations are counted by the number of words in the document title 

Link Bates/control numbers and testimony citations 

Requirements:  Those with Edit permission on both the Deposition and the Story can adjust the auto-convert setting.

By default, Auto-link Bates numbers and testimony references is switched on for each Storybuilder Deposition. This means that when you type a Bates/Control number or testimony citation, it is automatically turned into a reference that links to the evidence. To adjust this setting, select Settings, then switch off Auto-link Bates numbers and testimony references. 

Changing this setting updates it for all others on the Deposition. The setting affects future text written after the point that it’s toggled, but it will not retroactively convert/link (or unconvert/unlink) text or documents.

If the auto-link setting is toggled off, you will see a blue underline and suggestion to convert the text to a reference when Everlaw detects a valid Bates/Control number or testimony citation. Select Convert to document/Link testimony to turn this evidence into a reference. For documents, this adds the referenced document to the Deposition, as well as the Evidence page.