Six Tips to Ensure Your Deposition Runs Smoothly
Even in the best of circumstances, a deposition can mean a long and draining day for everyone involved. There are ways that you can make the next deposition you take run more smoothly and productively by planning ahead on how you’ll respond to issues that are sure to arise. Read on for several deposition tips, and contact our skilled and professional Phoenix court reporters for deposition services throughout the state of Arizona.
- Account for introductions and explanations in your schedule: Introducing everyone in the room to one another can take time, especially if both sides have brought a full team of attorneys to an important deposition. You may also need time to explain to your court reporter the exhibits, names, and vocabulary that they should expect over the course of the deposition. Make sure that time for these things is included in your schedule so that you don’t feel behind before the deposition has even begun.
- Remember to clarify a witness’ visual gestures for the record: Rather than forcing your court reporter to interrupt the deposition to ask for a verbal description of a visual gesture (i.e., a witness gesturing with their hands while saying “I was about this far away”), state in advance that witnesses should avoid these gestures, and be prepared to describe the gesture should the witness forget.
- Include regular breaks to remain sharp: If you believe that your deposition will last several hours, be sure to allow short breaks every two to two and a half hours, as well as a longer break for lunch. This will allow all participants to stay alert and engaged throughout the day, resulting in a more productive deposition.
- State clearly when you’re going off the record: It isn’t always possible to take a conversation off the record once you’ve begun talking. Keep in mind that you’re constantly being recorded, and remember to state that a portion of the conversation is off the record before you begin talking.
- Don’t speak over others: There are numerous reasons not to speak over others during a deposition, aside from the fact that it’s impolite. For one thing, your court reporter won’t be able to record the conversation accurately if two voices are heard at once, and important information could be missed. Second, sometimes a misinterpreted question could produce surprising results. Even if you think your question has been misunderstood, allowing the witness to speak without interruption could yield unexpectedly helpful answers to questions that you might not have thought to ask. Let them finish their thought before intervening.
- Have your exhibits ready to go: Have multiple copies of your exhibits numbered and ready to distribute to all those in attendance before the deposition begins. This will save the interruption of your court reporter having to add numbers and keep the exhibits organized during the deposition itself.