A Court Reporter’s First Deposition
A good start to any deposition is what you bring with you. Your machine, machine charger, a multi-plug-in extension cord, your laptop, laptop charger, machine-to-laptop cord, thumb drives, cell phone, cell phone charger, exhibit stickers, business cards or stickers, blue ink pen, red ink pen, paper clips, binder clips, rubber bands, sticky notes, cough drops, Kleenex, screen cleaners, the support number for your reporting software, job log and your assignment information and deposition notice. For realtime jobs, be sure to include an iPad, iPad charger, router and Wi-Fi card. It’s a good idea to bring snacks with you as well, like some fruit or a granola bar.
One day prior: Google Map the route to your job assignment location and determine how long it will take you to get there and what time you will need to wake up. Download the Waze app to your cell phone. Create a job dictionary for tomorrow’s assignment. Start with creating speaker identifications for the clients listed in your job information sheet and deposition notice, then create briefs for each name in the caption. For instance in the case of, The City of Arkenbark versus Joe Schmo, Tim Blonk, and Tina Grune, you will want each name identified and correctly spelled. The City of Arkenbark = STAOFK. Each brief should be something you easily write and makes sense to you. So maybe to write just Arkenbark, you might write AOFK.
Once your job dictionary is created, then create your job worksheet, either on paper or the digital firm worksheet. By being prepared, you will feel much more confident going into your first deposition.
Day of: Check your Waze app for the traffic conditions and plan your morning accordingly. You should arrive at your location 45 – 30 minutes prior to the scheduled start time. Ask if you can set up in the conference room as soon as you arrive. Set up at the head of the table where an electrical outlet is close by. In the event this is a video deposition, the witness is generally at the head of the table with you being immediately left or right of them. Ideally you want to be between the primary questioning attorney and the witness so you have the best opportunity to hear, as well as mark exhibits. Be sure to get business cards from attorneys and spellings of anyone else present in the room. Ask the witness to spell his or her name. Even if the Notice of Deposition shows the witness Joe’s name is spelled J-O-E S-C-H-M-O, be sure to verify that with Joe.
The Deposition: Start by swearing in the witness once everyone indicates they are ready to proceed. The first five minutes of any proceeding is always the most challenging to capture, so just hold on. Most attorneys have their own style of starting a deposition and it’s generally quite quick.
Generally, when exhibits are marked during the deposition, they will start with the number 1, however sometimes they would like to use A or perhaps start with another number. Be sure to ask what is preferred. It is your responsibility to keep track of where each exhibit is and what number or letter to mark next. The exhibits are your responsibility. Be sure you leave the proceeding with all original exhibits.
At the conclusion of the deposition, gather the exhibits and ask the attorneys if and when they would like a transcript. Complete your worksheet with start and end times, how many exhibits were marked, any special instructions, as well as each attorney’s order. Download your transcript, as well as your worksheet, to your thumb drive and store separate from your laptop and machine.
Now pack up and head for the office or home. You’ve done it! Congratulations!