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Let me preface this by saying that includes, parens, and block files are the SAME thing. Don’t let the terminology fool you. When I first started out, I was so overwhelmed. I hope this adds to your understanding of what a paren is and of which ones you need.

Parentheticals are words that weren’t said. The most common parentheticals you will use are Exhibit Marked, Off The Record, and Break. Because I am a minimalist, I keep my parentheticals to a minimum. Some people go on to note in which direction a head shake goes (left to right vs side to side) and others write parentheticals like (Witness Complied). I don’t use parentheticals that aren’t necessary.

I don’t think you need to put that a witness complied because it is a given. The attorney would make a reference to it, if the witness didn’t comply and it mattered. We are to take down words, not gestures. If I just see a head shake, I will just put (No Audible Response). I’m not going to say (Head Shakes) or (Head Shakes Side to Side). There is no need. You want to make your job easier for realtime. Streamline your life and keep things simple.

Some firms still use lengthy parentheticals (Whereupon, + 3 lines). Don’t fight it. If your firm does that, just consider it a page rate boost. The only downside to a long paren is that it looks and sounds antiquated. That’s it.

I recommend getting your parens from your mentor/firm, but I’m going to go over the parens that I use so that you know which ones to keep. Your firm/mentor will probably give you many, and your job will be to just use ONLY the ones that are necessary. Note that every paren can be added after the fact, so don’t stress.

Includes are only different from parens in that they are larger (usually a page or multiple pages long, not just a paragraph), but they act in the SAME way as parens. They will read into your document the same way. So just think of includes as large parens. People refer to these as block files also, which is just a fancy term. Again, block files, includes, parens = same thing.

Break – break was taken from __ to ___
Brief Interruption – when a phone rings, usually
Readback – CR read back the requested testimony
Clarification – CR seeks clarification (for when I interrupt because I can’t hear or understand)
No Audible – A. (No Audible Response)
Sworn In – wit has been sworn in
Examination – EXAMINATION comes up in capitals and centered, comes up after wit is sworn in or when a new attorney starts questioning
Further Examination – centered also, comes up when the attorney goes back for more questions (don’t complicate your life by doing Cross-Examination, Cross-Cross-Examination; Further Examination is adequate to cover all of it.)

Exhibit – exhibit marked and attached here
Exhibits – exhibits (multiple at one time) marked and attached here
Exhibit Retained – when attorneys say, “Please provide me a copy of your CV later, and we will mark it as Ex 5. Paren needs to say “retained by counsel” instead of “attached here.” ALSO, use this one when in court because exhibits are ALWAYS retained in court.

Depo Include – Cover page, Appearance page, Index page – make it read in automatically every time a job starts (more on how to do that in another post)
CourtBeginning – Court Cover page, Apperance, Index, Intro (delete Basic Depo Include and feed this in when in court by writing COURB or feeding in manually with ALT+R).
Court Ending – court include to end proceedings, comes up when I write COURND, or if I feed it in manually with Alt+R.
Open Hearing – (hearing is less formal than a proceeding, usually in a room (not a courtroom), but very similar) – opens my hearing include, and I use same ending as a Court Ending
Open Arbitration – arbitration includes, (arbitration is when something is settled by a group/board, not one judge/official), use same closing include as court
Rough – delete Depo Include and replace it with this IF they are ordering a rough draft because it is NOT supposed to look like a formal document – says something like, this is just a draft, there will be errors, do not quote from it, in so many words.

Conclude Not (actually a paren) – conclude paren after depo ends saying time, that signature is NOT waived
Conclude Waived (a paren, not include) – conclude paren after depo ends saying time, that signature is waived
Errata page – second to last page of a transcript, used ONLY if signature is not waived, the correction sheet, essentially
Cert page – very last page of a transcript certifying that you did the best you know how to and certify that this is true and accurate

Finally, to make things extra efficient (because I love efficiency), I have COMBINED the Conclude Not paren, the Errata, and Cert page into ONE paren called DONESIGNOTWAIVED. At the end of the depo, I write K-K/K-K/NOT, and all of this pops up. If I forget to write that, I can easily write it in while editing with Alt+R. This saves a lot of time of finding three different parens.

I also have another paren called DONESIGWAIVED that is almost exactly the same as DONESIGNOTWAIVED, only WITHOUT the errata sheet and noting that signature was waived. I write K-K/K-K/WAIVD, and it pops up. (K-K, for those who are curious, is the brief for conclude.) Can also read it in manually with ALT+R, if you have a memory as poor as mine haha

More on how to create a paren with examples of my parens in a post coming soon!

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