Tips for Preparing for a Non-Stenographic Deposition

1. Know the technology: Before the deposition, make sure you are familiar with the recording equipment being used. If it is a video deposition, test the camera and microphone to ensure they are working correctly. If it is an audio deposition, test the recording device to ensure it is picking up sound clearly. Additionally, make sure you know how to operate the equipment and what to do in case of technical issues.

2. Provide clear instructions to the witness: Explain to the witness how the non- stenographic deposition will be conducted and what to expect. Let them know that they should speak clearly and at a reasonable pace so that the recording device can capture their responses accurately.

3. Prepare your questions in advance: Develop a list of questions to ask during the deposition, and make sure they are relevant to the case. This will help you stay organized and focused during the deposition and ensure that you cover all of the necessary topics.

4. Consider using visual aids: If the deposition will be conducted remotely, consider using visual aids such as slides or documents to help illustrate your questions. This can be especially helpful if you need to review complex information with the witness.

5. Review the recording after the deposition: After the deposition, review the recording to ensure that all of the responses were captured accurately. This will also help you identify any technical issues that may have affected the recording.

6. Be prepared for objections: Just like with traditional depositions, objections may arise during a non-stenographic deposition. Be prepared to respond to objections and know how to handle them appropriately.

7. Hire an experienced court reporter: If you are using a court reporter for a non-stenographic deposition, make sure they are experienced and knowledgeable in using the technology and techniques required for the deposition.

Overall, preparing for a non-stenographic deposition requires careful planning and attention to detail. By following these tips, you can ensure that the deposition is conducted smoothly and accurately, and that you gather the information you need to build a strong case.

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