How to gain Maximum effect with videotape depositions

Control the Client's Image
Help the deponent get comfortable. Ask the deponent to wear comfortable clothing. Look out for tight cross-hatch patterns (herring bone, etc.) in the fabric which may cause a moire effect, a video/electronic effect that looks like the fabric is moving.

You don’t want the witness to stare into the camera; however, when they do talk to the camera they are looking directly at the viewer and this can be very effective. Use the phrase "Would you tell the Judge/Jury" and with this request the witness should look directly into the camera and answer the attorney’s question.

If the room is warm have them remove their jacket or sweater (preferably before we start). Watch out for perspiration or nervous twitches. If the room is hot, mention it on tape so the people viewing the tape are made aware of this. Be aware of the deponent’s audio level.

If interrupted, ask the question again.
The videographer may interrupt the deposition to bring up a Technical Problem that needs to be addressed immediately. Problems include exterior noise problems, microphone failure, electrical hums, camera failure etc. If interrupted, please pause immediately and we will go off the record.

The videographer will bring both dark blue and gray backdrops. The choice of color or whether to use a backdrop screen at all are up to the attorney present.

Please try to find a good room that will accommodate us successfully. Avoid loud air conditioners or buzzing fluorescent lighting. Too much street noise gets distracting as well.


Use Video Depositions for Impeachment Purposes

Edit Tape Before Trial, keep questions and answers together

No Whispering

Sotto Voce is ineffective with each individual being wired for audio. We use professional microphones and they pick up everything. All spoken words, including whispering, will be heard. Please ask to go off the record if you don’t want what you are saying on the record.

The videographer will use cue cards to warn you how much tape is left. 10 minutes, 5 minutes and 1 minute. Please pay attention to these cards.

Please do not hesitate to call or email us with questions. We are here to assist you.