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Giving A Deposition With Unwieldy Documents

by Sid Allen

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Deposition Tips

giving a deposition with lots of docs sucks

Giving a deposition is quite often a very pleasurable experience. Litigators get to face off against ornery ex-husbands, dimwits, people playing stupid, and maybe, if they're lucky, even arrogant celebrities. Dealing with the difficult witness when giving a deposition is a tough task, but often unavoidable.

Problems with giving a deposition if you have unwieldy documents

There are many situations that can create a deposition nightmare beyond who the witness is. One that litigators (or their paralegals) shouldn't have to worry about is dealing with unwieldy documents. Unwieldy documents are any non-standard document that have to be considered special during the preparation and conduct of the deposition. Examples include:

  • documents with a huge number of pages
  • color, hi-resolution, pictures
  • 3d exhibits (topographic maps, CAD drawings, models)
  • large documents such as blueprints, maps, or posters
  • documents with small print like spreadsheets, or contracts with fine print
  • electronic communications (emails, SMS, texts, screenshots)

If a case has a lot of these kinds of documents, giving a deposition with these in your luggage can be a nightmare, no to mention preparing multiple copies for all the participants. How are these issues addressed today?

Current Workarounds (Which Don't Really Work)

  • Blow up documents with fine print to make them more readable.
  • Print on both sides to save printing and shipping costs.
  • Print in black and white to save printing costs. Of course, a lot of information can be lost when replacing color with black and white.
  • Attorneys can simply pay more to have the color and oversized documents reproduced to scale. Of course this doesn't eliminate the pains associated with having to take these massive documents to a deposition.
  • Print in standard size, which will possibly change the dimensions of the document.

The Solution

All the workarounds listed above are how the professionals in the legal industry have worked to minimize the pains of giving a deposition with unwieldy documents. They aren't solutions. However, litigators who take depositions often with unwieldy documents can completely solve this problem by adopting deposition software.

Deposition software allows attorneys giving a deposition to leave the large rolls of blue prints in their office, to present color images in their true state, and not worry about bringing a magnifying glass so the witness can read fine print. Using deposition software, the attorney can store all these unwieldy documents in the cloud in their original state, and then present them to the witness with the click of a button. The document isn't confined to the width of the computer screen, and the witness can zoom in to read fine print or get more detail. Participants don't have to worry about flipping through 1000-page documents to find the quote you want them to look at.

Giving a deposition can often be stressful, things never go as planned, and the stakes are high. Smart litigators won't leave to chance the risks and pains involved with dealing with unwieldy documents. Forward-thinking litigators are giving depositions using deposition software, and making unwieldy documents a distant memory.










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