Rule 1006 Summaries of Voluminous Records
Clear summaries of large records, with every figure traced to its source.
Our approach
Counsel Sets the Method
Federal Rule of Evidence 1006 lets a party prove the content of voluminous records with a summary. We build that summary. Counsel decides the method and the assumptions. We apply them the same way to every record and show our work.
Every Figure Traced
Each number in the summary points back to the page or record it came from. Anyone checking the work can follow it.
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
Who decides the method?
Counsel does. We prepare the analysis from the records. Your attorney reviews, certifies and signs. We don't give legal advice. You set the method, the assumptions, and the periods. We apply them and document each step so they can be checked.
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?
If the summary needs a declarant or a witness, we discuss that during scoping and arrange it as part of the engagement.
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.
Have a matter that's drowning in pages?
Tell us about the matter and we'll scope it on a short call. Then we quote, run a conflict check, and get to work.