How to Cite Deposition Testimony Correctly (Page-Line, Timecodes, Exhibits)

To cite deposition testimony correctly, use the format your court expects and match it to the source you are quoting: page-line citations for written transcripts, timestamp/timecode references for video depositions, and clear exhibit cites for documents shown or marked. Your goal is simple: make it easy for the judge and opposing counsel to find the exact words you rely on. This guide shows the most common litigation citation styles, examples of correct and incorrect cites, and a checklist to avoid mis-cites that can weaken motions and briefs.

Primary keyword: cite deposition testimony

Key takeaways

• Use page:line cites for a transcript and timecodes for video when the court or record uses timestamps.
• Always identify the deponent, the date, and the source (transcript vs. video) so the cite is unambiguous.
• When citing exhibits, include the exhibit number/letter and any internal page label (e.g., Bates or page number).
• Never “approximate” a cite; verify it after formatting changes, condensed transcripts, or new versions.
• Build a quick cite-check routine to catch wrong lines, wrong versions, and missing exhibit identifiers.

What counts as “correct” when you cite deposition testimony

A correct deposition cite lets a reader locate the quoted testimony fast, without guessing which transcript, which version, or which part of the record you mean. Courts and local rules can vary, so you should follow your jurisdiction’s style first and then use the conventions below as a practical baseline.

In most litigation practice, a solid cite answers four questions in one short parenthetical: who spoke, where the words appear, when the deposition occurred, and what source you used. If you cannot answer all four, your cite is at risk.

• Who: Deponent name (and sometimes “Dep.” or “Tr.” label).
• Where: Page and line range, or timecode range, or both.
• When: Deposition date (often included at first reference or in a citation table).
• What: Transcript, video, errata-corrected version, or exhibit.

If your court requires pinpoint citations, page-line is the most common approach for transcripts because it stays stable across filings. If you are using video clips or the record is anchored to timecodes, a timestamp cite helps the reader jump directly to the moment in the recording.

Page-line deposition citations (transcripts): when to use them and how to format them

Use page-line citations when you rely on the written deposition transcript, including PDF transcripts, E-Transcripts, and most certified transcript formats. Page-line citations work best when your transcript has fixed pagination and numbered lines, which most deposition transcripts do.

Common page-line formats (pick one and stay consistent)

• Single pinpoint: Smith Dep. 45:12
• Range on same page: Smith Dep. 45:12–18
• Range across pages: Smith Dep. 45:22–46:4
• Include date (often at first use): Smith Dep. (Jan. 3, 2026) 45:12–18

Some lawyers use “Tr.” instead of “Dep.” or add “at” (e.g., “Smith Dep. at 45:12–18”). Either can be fine if your court accepts it, but consistency matters more than the tiny style choice.

Correct vs. incorrect page-line examples

Correct (pinpoint and readable):

• Jones Dep. 112:3–10
• Jones Dep. (May 14, 2025) 112:3–10
• Jones Dep. 112:25–113:6

Incorrect (hard to locate or ambiguous):

• Jones deposition, p. 112 (missing lines, not a true pinpoint)
• Dep. at 112:3 (missing deponent name)
• Jones Dep. 112 (missing line numbers)
• Jones Dep. 12:112 (page/line reversed, likely a typo)

Page-line pitfalls that cause mis-cites

• Condensed transcripts: If you cite a 4-up condensed printout, the “page” may not match the certified transcript pagination.
• Different versions: An errata-corrected transcript can shift text; your cite must match the version you file.
• Missing “line numbers” view: Some viewers hide line numbers; turn them on before you cite.
• Off-by-one line errors: A line wrap or formatting change can trick you if you copy text without verifying the exact lines.

Timestamp and timecode citations (video depositions): when to use them and how to format them

Use timecodes when you cite video deposition testimony, especially if you will play clips at a hearing or trial, or if your working record is organized by timestamps. Timecodes help the reader go straight to the moment in the recording, which page-line alone cannot do.

Time references appear in different ways depending on the tool used to record or synchronize the deposition. Your case record might include:

• HH:MM:SS timestamps (e.g., 01:23:45).
• Time-of-day stamps (e.g., 10:14:22 a.m.).
• Embedded timecode tied to the video file (common in synced video/transcript players).

Practical timecode formats

• Video only: Smith Video Dep. (Jan. 3, 2026) 01:23:45–01:24:10
• Video + transcript pinpoint: Smith Dep. 45:12–18 (video 01:23:45–01:24:10)

When you can, include both page-line and timecode for the same quote because it reduces disputes about what was played versus what was read. If you must choose one, follow the rule or practice that governs the filing.

Correct vs. incorrect timecode examples

Correct (clear range and source):

• Lee Video Dep. (Mar. 2, 2025) 00:17:12–00:17:40
• Lee Dep. 22:7–14 (video 00:17:12–00:17:40)

Incorrect (not verifiable):

• See video at 17 minutes (not precise)
• Lee video 00:17 (missing seconds and range)
• Lee Dep. (video) 22:7–14 (unclear if the cite points to transcript or video)

Timecode pitfalls to watch

• Different players show different clocks: “Elapsed time” may not match embedded timecode.
• Clip exports: A trimmed clip may start at 00:00:00, so your cite should identify the original recording timecode if possible.
• Breaks off camera: If the video pauses during off-the-record discussions, the timecode may jump compared with the transcript flow.

How to cite deposition exhibits (and testimony about exhibits)

Exhibits create two related citation needs: you may need to cite the document itself, and you may need to cite the witness’s testimony about it. Treat these as two separate pinpoints when it matters.

Citing the exhibit itself

A clean exhibit cite usually includes the exhibit identifier plus a stable internal locator, such as a Bates label or page number printed on the exhibit. If the exhibit is a multi-page document, always pinpoint the page within the exhibit.

• Example (exhibit only): Ex. 12 (Email thread), GT000123–GT000125
• Example (pinpoint page): Ex. 12, GT000124
• Example (no Bates, use page): Ex. 12, at 3

Incorrect exhibit cites often omit the key locator:

• See Exhibit 12 (no pinpoint)
• Ex. 12, email (not uniquely identifiable)
• Ex. 12, p. 1 (may be ambiguous if the PDF viewer renumbers pages)

Citing testimony about an exhibit

When you quote what the witness said about the exhibit, cite the deposition page-line (or timecode) for the quote, and then cite the exhibit separately if you also rely on the document’s content.

• Example (testimony + exhibit): Garcia Dep. 78:9–79:2 (discussing Ex. 12, GT000124)
• Example (testimony only): Garcia Dep. 79:15–22

This two-part approach prevents a common problem: citing only the exhibit when the proposition actually comes from the witness’s words, or citing only the transcript when you also need the underlying document.

A step-by-step workflow to avoid wrong cites in motions and briefs

Mis-cites often happen when teams move fast: excerpts get re-paginated, quotes get copied from email strings, and exhibits get renumbered before filing. Use a simple workflow to keep citations stable from draft to final.

Step 1: Lock the source you are citing

• Confirm whether you are citing the certified transcript, an errata-corrected transcript, or a rough draft.
• Confirm whether the video you cite is the full recording or an exported clip.
• Save the exact file name/version in your matter workspace so the team cites the same record.

Step 2: Pull quotes with their pinpoints attached

• When you copy a quote, copy the page:line range (or timecode range) at the same time.
• Keep quotes and cites together in a “quote bank” document so you do not re-find them later under deadline.

Step 3: Standardize your citation format early

• Pick one format for each source type (transcript, video, exhibits) and use it everywhere.
• Decide whether you will include deposition dates in every cite or only at first reference.

Step 4: Verify every cite against the final PDF set

• Open the final transcript PDF and confirm that the cited words appear exactly at the cited lines.
• Open the final exhibit PDF and confirm the pinpoint page/Bates label matches what you cite.
• If you include timecodes, confirm the cited range in the same player your team uses for prep.

Step 5: Build a quick “two-person” cite check for key briefs

• Have one person read the brief and call out each cite.
• Have a second person locate the cited text in the transcript/video/exhibit and confirm it supports the proposition.

This last step catches the most damaging errors: a correct page-line cite that points to the wrong proposition, or a quote that subtly changes meaning when pulled out of context.

Checklist: prevent mis-cites that undermine credibility

Use this checklist before you file a motion, response, reply, or declaration that relies on deposition testimony.

• Deponent ID: Did you include the correct witness name (and not another witness with a similar surname)?
• Date/version: Are you citing the right deposition date and the correct transcript version?
• Pinpoint accuracy: Do the cited lines contain the quoted words (start and end lines included)?
• Ranges: Are your ranges tight enough to be helpful but wide enough to include the full answer?
• Context: Does the surrounding question/answer change the meaning?
• Objections: If an objection matters to the argument, did you include it or note it accurately?
• Exhibits: If you reference an exhibit, did you include its number/letter and a pinpoint (Bates/page)?
• Video: If you cite timecodes, did you confirm they match the original recording and not a clipped export?
• Consistency: Are you using one format throughout (same punctuation, same abbreviations)?
• Final pass: Did you re-check cites after any last-minute edits, swaps, or renumbering?

Common questions

Do I have to use page and line numbers when I cite a deposition transcript?

Often, yes, because page-line pinpoints let the reader find the exact testimony fast. If your court has a different required format, follow that rule and keep your citations consistent across the filing.

Should I cite the deposition date every time?

Many lawyers include the date at the first citation and then omit it later, while others include it every time for clarity. If you have multiple depositions of the same witness, repeating the date can prevent confusion.

How do I cite a video deposition if I only have a transcript?

If you are not relying on the video, cite the transcript with page-line pinpoints. Only add timecodes if you can verify them from the actual recording or a reliable synced transcript tool.

What is the best way to cite testimony about an exhibit?

Cite the testimony with page-line (or timecode) and cite the exhibit separately if you rely on what the document says. This makes your support easy to track and avoids mixing up the witness’s words with the document’s content.

How do I cite errata changes?

First, make sure you are using the version of the transcript that includes the changes you rely on. If your filing discusses the change itself, cite both the original testimony lines and the errata page or attachment where the change appears, using the labels in your transcript set.

Can I cite to a condensed transcript printout?

You can use it for review, but it can create confusion if its pagination differs from the certified transcript. For filing, use the certified transcript page and line numbers so the court can locate the testimony reliably.

What if my cite is correct but the quote is slightly paraphrased?

Paraphrases still need accurate pinpoints, and they should not change the meaning of the testimony. If precision matters, quote directly and keep the citation range tight.

Where transcripts, captions, and formatting can help

Citation accuracy depends on having a clean, readable record with stable page and line numbering and clear exhibit labeling. If you work with audio or video outside the deposition context (client interviews, witness prep recordings, internal investigations), getting a reliable transcript early can make later referencing and quoting much easier.

If you need help preparing accurate text from audio or video and keeping it organized for review, GoTranscript offers professional transcription services that can support a clear workflow from source file to usable text.