Taking a “good” deposition can help you settle the case your client’s way.  Expert litigators have been able to win cases based on the quality of the deposition reflected in the transcript.  Below are 8 tips that can help you make this a reality.

• Context – Providing spellings of proper names, technical terminology, attorney names, and a caption before a deposition begins can help us to create a cleaner transcript with faster turnaround time.

• Special Circumstances – Giving us advance notice that the deposition will be “realtime,” expedited, requiring a rough, etc. can ensure that it runs as fast and efficiently as possible with a quick turnaround time.

• Timeout – Short breaks every hour or two not only help us rest and stretch, but also help with our endurance throughout the day.  A long day with very few breaks may actually impede the integrity of the transcript.

• Fast Talkers – A 3-second pause in between the questions and answers can help immensely.  They allow us to catch up and prevent us from having to interrupt and slow everyone down. 

• Arguers – Heated arguments are often unavoidable, but you should know that if you want what you’re saying on the record, you must try your best not to interrupt and talk over others.  Otherwise, it is virtually impossible to get it down.

• Mumblers – A mumbler is usually more difficult to take down than a fast talker, so please speak up clearly, and avoid covering your mouth with your hands.

• “Exhibit A” –When assigning exhibit markers, please pause a moment so we can mark them.  We can’t type and mark at the same time. 

• Video – Beware:  Everything that can be heard on the video will be transcribed.  We mean “everything.”

We hope you enjoy.