Rule 1006 Summaries of Voluminous Records
Federal Rule of Evidence 1006 lets a court admit a summary, chart, or calculation to prove the content of voluminous admissible records. We prepare the summary and its workpapers for counsel’s review.
Our approach
Counsel Sets the Method
Rule 1006 permits summaries of voluminous admissible records that cannot conveniently be examined in court. We prepare the summary and source workpapers using counsel's method and assumptions. Counsel addresses admissibility and access to the underlying records. We also prepare record summaries for state and local courts and administrative proceedings under the requirements counsel identifies.
Source references
The summary’s source index identifies the records used for its figures. Calculation steps and assumptions are documented so counsel can review the work.
Damages and Exposure
The same work serves either side of a case. We can show both sides' assumptions side by side so counsel can see the difference.
Workpapers Included
You receive the summary and the workpapers behind it: the source index, the calculation steps, and the records each total depends on.
What We Summarize
Payroll and Time Records
Hours worked and paid, pay rates, and pay periods, reconciled across payroll and timekeeping systems.
Financial Transactions
Payments, invoices, and account activity, organized by party, period, or category.
Email and Communications
Counts, dates, senders, and recipients across large email sets, tied to the messages themselves.
Other Large Record Sets
Logs, spreadsheets, and database exports that are too large to put in front of a jury page by page.
Frequently Asked Questions
What should we bring to scoping?
Describe the records, relevant periods, proposed method and assumptions, and deadline. Identify how the underlying records will be available for examination or copying by other parties.
Who decides the method?
Counsel sets the method, assumptions, and periods. We apply them to the agreed records and document the calculation steps for counsel’s review.
Can you show both sides' numbers?
Yes. We can run the summary under each side's assumptions and present them side by side.
What if a witness is needed for the summary?
Tell us during scoping if a declaration or testimony may be needed. We confirm whether we can support that work and include any agreed arrangements in the scope.
How long does it take?
We confirm the delivery date when we accept the scope. Rush is available, with the fee and date quoted with the scope.
Need help with your next matter?
Tell us the task, record volume, and deadline. We scope the work on a 30-minute call, run a conflict check, and confirm the quote and delivery date before starting.