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Case-saving advice about video depositions By Doug vanderHoof |
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Your video deposition can be more persuasive if you get the basics right. I've been getting them right, and then some, since 1985. To bring all these basics to bear on your next deposition, |
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Here's a checklist I presented when ITLA invited me to teach a CLE unit on modern media in the courtroom. There's a lot more to a strong video dep but this list will help you compare shooters. |
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1.Hire carefully a. Get recommendations b. See their work c. Experience counts 2. Sit close to the camera, so the witness shows their face to the camera 3. Witness’s face is lit normally, no scary shadows |
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4. Undistracting background a. No windows, no modern art, no reflective surfaces 5. Prepare witness and shooter for exhibits a. Check before the dep starts that the camera can see exhibits well enough b. Decide on how the camera zooms in, on or off record c. The witness must give the camera time to get there and see it 6. Audio! Good video's secret weapon. a. Quiet room; turn off humming machines, close the windows if you have to b. Every speaker has their own lavalier microphone c. Microphones go to a mixer d. Shooter wears headphones and stays vigilant e. Cell phones and pagers silent and away from mic cables f. Balanced audio lines only. Ask if they're using it. 7. Objections and Editing a. If a question draws an objection, rephrase slightly and try again, and again b. Editing will perfect the record, hiding the objections 8. Check the recording a. When you get your copy, spot check to see that it looks and sounds right; be fussy, it’s your case |
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To schedule a video deposition, please call 773-394-0029 OR Use the online form here. Less than 48 hours notice? Please call immediately, 773-394-0029. Your deposition is too important to take any chances! |
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