This subject has given me more grief over the years than I want to admit.

I am just wondering what the opinions are on quoting material from an exhibit, such as, a heading that someone reads. Do you-all quote those pieces of read material or not?

What about when a witness just speaks in a pattern of: I said -- So she said -- And then I said --

This subject is probably very specific to each individual transcript and a lot of times depends on the way in which the witness said something, but anyone who wants to share their opinions, I would love to hear when you use quotes and when you don't :)


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I swing in a lot of different directions with this. Mainly, I try to be consistent throughout the transcript.

When reading QUOTED material, if the speaker of the quoted material does NOT follow the text, then I use a colon and no quotes, like this:

The Gettysburg Address says, and I quote: Four score and seven years ago, fathers brought forth on this continent, a new nation dedicated to the proposition that all men are created equal.

When reading QUOTED material, if the speaker of the quoted material reads the text, I use quotations marks, but, if the speaker does follow the text EXACTLY and skips words, I use the ellipsis within the quotes, like this:

The Gettysburg Address says, and I quote, "Four score and seven years ago...fathers brought forth...a new nation dedicated...that all men are created equal."

When reading QUOTED material, if the speaker of the quoted material jumps in and out of the text, I use the double hyphen, quotation marks, the ellipsis when applicable, like this:

The Gettysburg Address says, and I quote, "Four score and" -- was it six or seven? -- "seven years ago, our fathers brought forth" -- let me start over. "Four score and seven years ago...."

When quoting printed material, I drop down a new paragraph, use my parenthetical indentation (indent 10 spaces from left margin and 5 from the right) and quote it:
Exhibit 3, Request Number 1 asks for:
"Any and all documents from the
period of January 1, 2009, to January
15, 2009, including, but not limitied to,
bank records, blah, blah, blah."

As far as your he said/she said question, I do it like this:
A. So then I, like, saw her and said, "So where'd you go?"
"To the store."
So then I asked, "What for?"
She said, "Milk."
So then she says some thing about, "Mom said we
were out and the kids need milk for breakfast."

And, yes, I paragraph when the speaker changes.

As far as your heading of an exhibit with quoted material, I do this:

I'm reading from Exhibit 3, a letter dated January 1, 2009, "Re: Bob's
"Blah, blah, blah.................
"blah, blah, blah, blah................
"blah, blah, blah."

That's my two cents on the subject.

eta: my indents didn't take, so pretend the quoted material is indented 10/5.
Yeah, Judy. I'm with you on this. I'd do it just like that. Cynthia
Judy, I'm doing a bear of a transcript right now with this same issue ~ every line of every exhibit is being read in. The atty keeps saying, "It continues" or "He continues" or "The exhibit continues" ~ would you write, for example:
Q. Okay. It continues:
"Blah, blah, blah . . . "

Also, I'm coming across, and "you say" and "he says" because he's reading from notes and meeting minutes ~ should I colon, paragraph, quote then too??

grrrr, I'm not enjoying this transcript at all!
I would paragraph, double indent, and quote that type of stuff. If it's causing you that much trouble, you deserve to be compensated with a few more pages, you know?
That's what I do, Judy, for all quotes. Definitely helps the page count and it's only right, as you say. And for those deps with constant reading from documents, it really makes up for all the extra work dealing with breakneck speed of reading.
I'm not a fan of padding a transcript, but that's not padding. They throw something at us like that, we should be compensated fairly, IMHO.
If it's so complicated like that then don't put any quotes because how are you going to really know where they go? I just wouldn't quote and you will save hours of headaches
Thanks Jennie, Judy and Cynthia! That really did help clarify my quotes rules :) Thanks for taking the time to type that all out !

Have a great week!

I've done it different ways, but I now put a reporter's note at the beginning, right after the P R O C E E D IN G S line (so they'll see it) that says that (REPORTER'S NOTE: Quotation marks do not necessarily reflect direct/exact quote.). Then I just quote it and I don't worry if it's exact or direct.

I still go through the exhibits painstakingly to make sure I have the same punctuation and if it's capped, I'll cap it. I used to not put the reporter's note but put "(as read):" if they didn't read it perfectly.

This past week I took some depos for an attorney I have taken several deps for in a particular case. He got his 750 pages' worth of depos a day or two this last time, eleventh or twelfth business day; and when I saw him this time, he made a point to mention it. I explained that getting out 100 pages, 200 pages, in ten days is a breeze; but getting out 750 pages, replete with document-referencing/reading, well, that's a different matter altogether. I also told him I go through each exhibit he reads from into the record or has the witness read from, to make sure I quote it as it's done in the document--and that I hear correctly slurred words, if any (as often happens when reading). This is the part that got me: "I don't care about that if you can get it to me earlier."

Oooookay. He doesn't care. And, you know, I think most attorneys don't care about a lot of the things we fret about. No, I will just quote away this round of depos, and I'm not going to look at the exhibits once, not once. If an "and" should be an "in," a "the" should be an "a," next time maybe they'll pronunciate a little clearer--it's all about the clock.

Hmmm, maybe I'm gonna like this, come to think of it.
Well, now you have the benefit of his preference. Yeah, I think you are going to like it! But you know what? The totally indecipherable rushed slurring and and/in and the/a drive me so batty that I'd probably be looking closely at the quoted material nevertheless. But at least the parts that are fairly decipherable you can quote (and double indent of course) and not bothering finding it in the exhibits.

Very interesting your reporter's note. Will keep that in mind. "As read" is perfect for a video.

I don't have a P R O C E E D I N G S line in the transcript (except for the title page). Where do you put the reporter's note in relation to the witness sworn blurb?


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