– When you arrive at the deposition introduce yourself to the court reporter, state which parties you represent and provide him or her with a business card. Also provide the court reporter with a copy of the notice if one has not already been furnished.
- NO HUH-UHS, UH-HUHS OR INAUDIBLE GESTURES– A court reporter cannot write huh-uhs and uh-huhs and furthermore it is not always clear what is meant by these phrases. Both the attorney and deponent should speak loudly, clearly articulating each word. Avoid turning away from the court reporter when speaking and keep your hands away from your mouth. Remember every sound uttered will be a part of the record.
- STOP TALKING– When an exhibit is marked wait until the question is completely answered before handing the exhibit to the reporter. When handing over the exhibit stop talking. Remember it is the reporter’s duty to accurately preserve all communications during the proceeding and he or she cannot do so if questions continue to be asked while the exhibit is being marked.
- BREAK– Remember that it is impossible for the court reporter to eat, drink and go to the restroom during the proceeding. Short breaks allow the court reporter to take care of physical needs and return refreshed.
- PRECISION– If the terminology for the deposition is going to be riddled with acronyms and or difficult medical terms provide the court reporters with these ahead of time. Ask the deponent for clarification of words or names which sound alike and always ask for spelling of unusual names or phrases.
- SLOW DOWN– When reading from a document continue at your normal questioning speed. Include the words “quote” and “end quote” and provide the court report with a copy of the document.
- SIT STILL– Avoid rustling papers, tapping the table, clicking your pen and any other annoying habit which causes noise. The court reporter must be able to hear every word and cannot do so with distracting noises.
- WAIT– It is very easy to interrupt the deponent before he or she stops talking or for the deponent to answer a question prematurely. When the parties are constantly talking over each other it is impossible for the court reporter to capture everything that is said. Remind the deponent that only one person can speak at a time.
NAEGELI Deposition and Trial has been serving the legal community with professional and knowledgeable court reporters for over 35 years. Give us a call today at (800) 528-3335 or email us to schedule at deposition at firstname.lastname@example.org.