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Guide: The record

Multi-day depositions: volume numbering and continuous pagination

A deposition that runs past one day is commonly reported in numbered volumes, often one per day, each with its own cover page. Page numbers may run on from one volume to the next or restart at 1. Cite the volume whenever a page number could repeat. Reporters, courts and agreements differ, so check how yours is numbered.

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Information, not advice. This guide describes common practice for litigation staff. It is not legal advice. Rules differ by jurisdiction, court and judge, and orders in your case can change them. Check what governs your matter and ask your supervising attorney.

How volumes and page numbers work

Federal Rule 30(d)(1) sets a default limit of one day of 7 hours for a deposition, and the parties can agree to more time or the court can order it. A longer examination runs over several sessions, and reporters often package each one as a volume. State rules differ.

Each volume often repeats the caption and appearances and ends with its own certificate. The cover page and index show how the numbering runs. With continuous numbering, Volume II opens where Volume I ended. With restarting numbering, every volume begins at page 1, so a cite needs the volume, as in Smith Dep. Vol. II 12:4–9.

How to work across volumes

  1. Read each volume's cover page and index

    Look for the volume number, the date and the first page number. Does Volume II begin at 1, or where Volume I ended?

  2. Name the files by volume and date

    Use a name such as Smith_Vol-II_2024-06-15.pdf. “Day 2” can mean different things to different people.

  3. Choose the cite form

    With continuous numbering no volume is needed. With restarting numbers, include it. See page-line citation format and follow your court's form.

  4. Check the join between volumes

    A question can end one volume and its answer begin the next. Read the last page of one and the first page of the other.

  5. Carry exhibit numbers across

    Exhibit numbers often continue from day to day, but confirm that they do. See building an exhibit index.

  6. Convert each volume as its own file

    Compare each file's page range with its cover page. See transcript formats for what each copy keeps.

  7. Look for a certificate and errata per volume

    Each volume may carry its own certificate, and corrections may arrive for some volumes and not others.

Continuous and restarting pagination

AspectContinuousRestarting
Page numbers Volume II opens where Volume I ended, say at page 251Every volume opens at page 1
Cite Smith Dep. 312:4–9Smith Dep. Vol. II 12:4–9
Ambiguity A page number names one pageThe same number appears in several volumes
Searching A hit's page number is unique in the setAdd the volume to every hit
Index and exhibits One running index and exhibit series are commonEach volume may have its own index, and exhibit numbers may or may not continue
Main risk A missing volume shows as a gap in the numbersA cite with no volume is ambiguous
The cites are illustrations. Follow your court's form.

What goes wrong

  • Citing without the volume. Where numbering restarts, 12:4–9 can mean several different passages.
  • Guessing the numbering from one volume. Check the cover page of each volume, not only the first.
  • Two depositions of one witness. A second deposition can also have a Volume I. Add the date to the cite or the file name.
  • Combined PDFs. A single file that holds several volumes can repeat page numbers inside it.
  • Colliding exhibit numbers. A new Exhibit 1 on day two when the series was meant to continue.
  • An incomplete set. Continuous numbering shows a missing volume as a gap. Restarting numbering hides it.

How DepoScript helps

DepoScript reads each page's number from the printed page, so a volume that starts at page 251 keeps its own numbers, and the Checks tab shows the page range of each file. If a PDF prints no page numbers, set First page number under Options. Edit the Cite prefix to add the volume. It converts one file at a time and does not merge or compare volumes. Files over 10 pages are converted up to page 10 on the free allowance; a page code converts the whole file, up to 150 pages. Try the converter. Free: 1 file per day, up to 10 pages, no account. See pricing.

Questions

Why is a deposition split into volumes?

Usually because it ran over more than one day or session, and the reporter delivers each as a separate part. Practice varies by reporter.

How long can a deposition last?

Federal Rule 30(d)(1) sets a default of one day of 7 hours. The parties can stipulate to more time, and the court may allow more. State rules differ.

How do I cite a later volume?

If the pages restart, include the volume, for example Smith Dep. Vol. II 12:4–9. If they run on, many writers omit it. Follow your court's form.

Do line numbers also restart?

Line numbers run from 1 on every page, whichever way the pages are numbered, so a cite needs both the page and the line.

Do exhibit numbers continue across volumes?

They often do, but not always. Check the exhibit index and the marking language in each volume.

Can I convert all volumes in one file?

A file is limited to 150 pages, and page numbers can repeat inside a combined file. Converting each volume separately keeps the numbering clear.

How do I cite a passage that crosses into the next volume?

Give both ends, each with its own volume if the numbering restarts. Forms for a range across volumes are not standardised, so check your court's.

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