I’m assembling Rule 1006 summaries tracing wires across seven bank accounts over 36 months, sourced from subpoena returns and reconciled via Power Query to the general ledger. For those who’ve testified, what level of annotation (transaction IDs, counterparty notes, and Bates ranges) has persuaded the court without inviting objections, and do you file the reconciliation workpaper as a separate exhibit or embed key excerpts in the schedule?
I’ve had the best luck keeping the 1006 summaries to date/amount/txn ID, account, and a Bates on every line, with counterparty notes only in a backup crosswalk — “subtitles, not director’s commentary.” I don’t file the Power Query reconciliation; I produce it in discovery and bring a locked PDF extract plus a one-page field codebook, which has kept out commentary objections… Small caveat: one court wanted the cleaner version for the jury and a fully annotated appendix for the judge, so I show both in the exhibit list and reference Rule 1006. Summaries to Prove Content | Federal Rules of Evidence | US Law | LII / Legal Information Institute in the pretrial memo.