I want to take the time to offer paralegals and attorneys some helpful tips on how to book a videographer for your next deposition. You may think scheduling a time and date is all that’s needed, but in order for any deposition to run smoothly, some details are crucial for the videographer and their office. Although clients may not know at the time of scheduling, it’s important to get those extra requests and details arranged prior to the day of the deposition. These tips will prevent delays and headaches so everyone is prepared and the videographer that is best for the job is sent to that specific deposition.
Tip No. 1 – Notice
Receiving the notice when the deposition is scheduled is helpful for everyone! The notice is what videographers rely on for their read-on and deposition information. Without it, the deposition cannot begin. The main items we rely on are the witness’ name, case name, the court, case number, location of the deposition and what attorney is requesting the videographer. All of this information is essential for creating and making a great record so the video can be used during trial.
Another point I want to touch on is whether or not the notice says the witness can be videotaped. If it does not, then this gives us a good idea of whether or not the videographer is going to be able to actually videotape. We’ve recently been seeing attorneys putting language about videotaping on every notice so it is never a problem. If it’s not on the notice and the videographer is hired, most likely the opposing counsel is going to throw his hands up and say the deposition cannot be videotaped. Bummer, but this usually costs the attorney some time and money. CCP 2025.330(c) references this issue and further clarifies notices and videotaped depositions.
Tip No. 2 – Location
Consider the location chosen for videotaping a deposition. Consider the size of the conference room, doctor’s office, prison space or hotel room. Anything larger than a 10×10 room would be helpful for the videographer. If the videographer is great at their job, they will make any space work. Although, we videographers do understand that the location is sometimes dictated by the deponent’s situation and availability.
Tip No. 3 – Expert Witness
Will the witness or deponent be giving expert testimony? It’s important that the court reporting firm/videographer knows whether or not the witness is an expert because not all videographers are notaries. In a perfect world they all would be, but that’s not always the case. You do not want a problem later on down the road when opposing counsel tries to block the video from being used in court. Refer to CCP 2025.340(c) regarding this issue.
Tip No. 4 – Multiple Witnesses
Are all the witnesses needing to be videotaped? Are the videotaped witnesses scheduled back to back or out of order? Are they all at the same location? These are all questions the videographer will be asking and needing to know. Court reporters and videographers will cover a deposition with anywhere from two to five deponents in a day with one noticing attorney. It’s best to schedule the videotaped witnesses in order so the videographer can choose to pack up at an appropriate time without disrupting the next witness’ deposition. If the witnesses are at different locations, give plenty of time for the videographer to break down at one location, travel to the next location and have time to set up at the new location. As a point of reference, videographers should be able to break down and set up within an hour.
Tip No. 5 – Videographer Setup
Some attorneys and court reporters prefer the videographer to set up and videotape a specific way. Some attorneys will have the videographer videotape down the table versus across the table. If you’ve been on multiple videotaped depositions, you may have seen the different ways the videographer sets up and tapes. One tip I’d offer is if the attorney has a specific request on the setup, he/she should either disclose this during scheduling or arrive early to make sure this is done correctly. I know our office prefers to shoot across the table, with the court reporter at the end, and the noticing attorney next to the videographer so everyone can be near the witness. So knowing these preferences will help prevent delays and stress for everyone.
Tip No. 6 – Additional Requests
Technology is only growing as time goes on. In the video world, technology has expanded to include things like picture-in-picture or document cameras (like an ELMO) with an end product displaying both the witness and the exhibits. These types of details are crucial to learn at the time of booking so the right videographer can be booked and the right equipment can be made available. As we all know technology continues to change, and not all videographers are up to speed with only some having the ability to handle these assignments. The more notice the videographer or court reporting firm has on these special requests, the better the deposition day will go.
I hope you find these tips helpful. Now, are you wondering if you should synchronize your next videotaped deposition? Check out this blog Synchronize Or Not To Synchronize A Video Deposition? and any additional video blogs on our website!
As a court reporter and reporting firm owner, I often discuss different technologies with our clients. And in our industry, the technology-based offerings are many. Realtime, delivering a rough transcript instantaneously during the proceeding to attendees in the room and/or at another location, is obviously a popular subject. There is no question that there are those attorneys who love it and rely on it for their notetaking and then there are those that use their trusted yellow legal pad and their keen notetaking ability. I get it. I do most things these days on my computer or iPad, but there are times when a paper copy or a good pad of paper is the best choice. We recently had a few instances come up that reminded me that realtime is not just for notetaking. It can solve other issues that may come up in a deposition.
One thing that we see often is the use of realtime for someone who is hard of hearing. As a matter of fact, my first realtime job some years ago was for a client who was hard of hearing. The client explained to me that with age he was losing his hearing. Although he still functioned well, he hated to have to keep asking witnesses to repeat what they said or to continually ask me to read it back. For him my realtime screen made doing his job easier and avoided perhaps misunderstanding something the witness said.
For depositions where interpreters are needed, realtime can help speed up the flow. And if you are bound by the seven-hour rule, realtime may be something to consider.
We had a case where all the parties and witnesses needed an interpreter. It became apparent early on that this would be a slow process. It wasn’t the interpreter’s fault but the complexity of the case together with objections and interruptions. There was a lot of reading back or restating the question. This can be dependent, I suppose, on how the interpreters work, either translating simultaneously or waiting for the end of the statement before they begin the translation. In this case we added the realtime screen for the interpreter. It instantly became easier for the interpreter to stay on track and for the depositions to move at a quicker pace.
Realtime can also be helpful for those witnesses who might have a thick accent or even a speech impediment. By putting the realtime screen in front of them, they can review what the reporter reported and correct the misunderstanding immediately.
The last thing I wanted to touch on was sending realtime to an attendee remotely. You may have an expert or party that would like to attend a deposition but cannot. It is as simple as having the reporter email a link so they can follow along and read the testimony. Of course, with a camera added, they could also see the witness and follow along with the testimony. If you would like to be able to chat or interact with that person, a non-discoverable chat function can be added as well.
So realtime at your next deposition for notetaking may not be what you need, but you may come upon a situation where it may be just what is needed. And did I mention there is no longer a need for cords and tokens? The reporter can bring out a sleek iPad or tablet and your “problems” may be solved.
To learn more about remote attendance and scheduling tips, check out our article on 5 Scheduling Tips for Videoconference Depositions.
FOR IMMEDIATE RELEASE – June 25, 2018
Wood & Randall, a court reporting firm, celebrates doing business from their location in Fresno, CA, for fifteen years. Wood & Randall provides court reporters, legal video services, videoconferencing, conference rooms, and other court reporting services.
Wood & Randall was founded in Bakersfield, California, over thirty-six years ago in January 1982. The firm is currently the largest court reporting firm with an in-house legal video department based in the Central Valley of California.
Christine Randall, owner of Wood & Randall, stated, “We’re thrilled to be celebrating doing business in our Fresno location for fifteen years. It’s not always easy for a business to decide to open additional locations. However, after we had been serving our clients throughout the Central Valley in California from our Bakersfield location for over twenty years, we saw a need for us to open up a location in Fresno. At our business’ core is the philosophy of ‘Moving Forward with Technology and Excellence.’ Wood & Randall identifies the needs of our client and exceeds their expectations. This philosophy and practice of providing excellent service and state-of-the-art litigation support is behind everything we do. There was a need for our clients to have access to professional conference room space in Fresno. We decided to go for it.”
Christine continued, “After starting with one small conference room, we received confirmation that there was indeed a need for the space and expanded to two large conference rooms. Then, about three years ago we moved into a newly renovated space that we are in today. We hired one of the top local interior designers to create an environment with our 4 conference rooms that attorneys would feel great about bringing their clients to for depositions, arbitrations, mediations, and any other meeting they have.”
Positive reviews from Wood & Randall clients verify their high level of service.
Lisa U. stated, “Our clients travel to Fresno frequently and need a conference room, court reporter and videographer for their depositions. Wood & Randall's Fresno office is the perfect setting & their staff is outstanding in every way. They are my first call for the Central Valley and I would highly recommend them.”
Jan Schmitt stated, “Wood & Randall in Fresno have far exceeded my expectations. Their offices, staff and reporters are professional, friendly and offer the best in customer support. I highly recommend them!”
Steven Gibbs stated, “Great fast service, friendly reporters and convenience. Easy to work with for short and long jobs!”
Lisa Given stated, "Our law office has used Wood & Randall for many year. Their service is impeccable and staff is always responsive. They strive to meet our needs – even when that need seems impossible!"
Christine Randall concluded, “We’ve really enjoyed working with our clients from our Fresno location for fifteen years and look forward to many more!”
Wood & Randall has locations in Bakersfield, Fresno, Visalia, and Valencia, CA. Their court reporters and videographers are highly skilled and are experienced in covering all types of legal proceedings. They provide court reporters, videographers, and other court reporting services throughout the Central Valley and across the nation.
The Fresno office information is:
Wood & Randall
516 W Shaw Ave #200
Fresno, CA 93704
To schedule a deposition or find out more information about Wood & Randall, visit http://www.bakersfieldcourtreporter.com/ or call (800) 322-4595.