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I don't know that summary notes and prose summary are technical terms, but if I were to take a guess, I would assume that one is less formal than the other.
As a teacher, if I gave an assignment to write a "note" of summary, or to take "summary notes," I would accept bullet points, lists, and incomplete sentences as correct. Generally, the objective of such an assignment would be to make sure students had the basic understanding of the plot line or details of a text.
If I gave the direction to write a "prose summary" on the other hand, it is likely that I am looking for a couple of things. First, of course I want to see that my students understood what they read and included necessary details in the summary. Additionally, prose suggests that this summary needs to be written in complete sentences, and likely these sentences need to form complete paragraphs. Not only am I assessing basic understanding of textual details, but I'm looking for technical correctness and writing skills as well.
A prose summary is when you asses the grammar, diction, and tone used in the piece read to give a better explanation of the theme.
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