Stop Making Your Witness Dig Through 50 Pages

A better way to prep large deposition exhibits

If you’ve ever handed someone a thick document/exhibit and said, “go to page 17,” you already know how this goes. Page flipping. Awkward silence. Someone lands on page 16. Then page 19. Then asks, “wait, which one again?”

Meanwhile, the flow of the deposition dies.

The Simple Fix: Extract Key Pages

Here’s the move, and it’s way simpler than it sounds: pullout the important pages and make them their own exhibits.

Let’s say you’ve got a 30-page police report. That whole thing can still be Exhibit 1. But if the key moment is the accident scene diagram and narrative on pages 7 and 8, extract those and make them Exhibit 1.1.

Now instead of sending the witness on a scavenger hunt, you’re putting exactly what matters right in front of them.

“Take a look at Exhibit 1.1.”

Clean. Fast. No confusion.

Why This Works So Well

Extracting key pages gives you way more control during questioning. You’re not competing with irrelevant pages or extra material that pulls attention away from your point. It also keeps things moving. The witness knows exactly where to look, and you don’t lose momentum flipping through along document.

Capture the Annotation, Not Just the Moment

Here’s where it really pays off.

If the witness marks up the accident diagram, circles something, draws arrows, whatever, that annotated version becomes Exhibit 1.1A.

Now you’ve preserved exactly what they did without touching the original.

That matters later. You’ve got a clean record of what the document looked like before and after their testimony.

This Is the Stuff That Makes Depositions Better

This approach:

• Keeps the deposition moving
• Makes it easier for the witness to follow along
• Gives the attorney tighter control of the narrative
• Creates cleaner, more useful exhibits

It’s a small prep step that makes a big difference once the deposition starts.

Take the Extra Minute

Next time you’re organizing exhibits, don’t just drop in the full document and move on. Pull out the pages that actually matter and give them their own exhibit number. Everyone in the room will feel the difference.

‍