Introduction to Deposition Preparation and Strategies

Taking Depositions with a Video Camera (2:17 and 10:35)

Let's expand on a few things.

First, as always, know your rules. If you're going to be the one operating the camera and swearing in the witness, then be sure to know what is required of you.

For example, you may need to become a notary so you can swear in the witness.

Additionally, you may also need to make statements once the video recording begins that notes that everything is on the record and what time it is.

Second, if you can have both a court reporter plus a video camera, then definitely do it!

Not only will the paper record make things easier when citing the record in pleadings, but the video record will put in perspective how the question is answered by the witness.

For instance, the paper record may look like this:

Q: You're at fault, correct?

A: No.

Seems straightforward, right?

In reality, the transcript has a major limitation -- you can't see how the witness is responding.

In reality, before answering the above question, the witness may have waited 5 minutes before saying anything. In doing so, the witness may have also been sweating profusely, looking around nervously, and dressed inappropriately. 

The video in this situation is obviously going to have a MUCH bigger impact on the jury.

Third, master the video camera before using it at a deposition.

The last thing you want is to take a deposition that is not recorded.

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Discovery Requests - Defined for Civil Cases (8:30)

Interrogatories. A list of questions sent to another party that must be either objected to or answered (in whole or in part). The answers need to be sworn to, which requires a notarized verification to be attached with the answers.

Request for Disclosures. Generic questions or requests -- set by statute -- that the parties send to one another.

Request for Production. A request for documentation, stored information, and/or tangible things.

Request for Admissions. A set of statements sent to the other party for the purpose of having the recipient either admit or deny the validity of the statements.

The Traditional Strategy with Depositions

What are your thoughts with this approach? Let me know in the comments down below!

Alternative Deposition Strategies

Here are just a few deposition strategies that I've used in the past!

These are just two of many alternative options, which means that you'll need to determine which strategy is best for your case.

Just be mindful that every wave of Discovery Requests is going to burn a chunk of time (typically a month of time).

The last thing you want to do is to have too many waves that ultimately put you close to the discovery deadline. 


If you have any questions, comments, or thoughts, then be sure to leave those in the comment section below!

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