Pre-Deposition Tips: How to Prepare to Take a Deposition- Plaintiff’s Perspective

by: Prince, Glover & Hayes Tuesday, June 15th, 2010

Types of Depositions- Continued

Some Advantages of Videotaping a deposition

There are advantages to videotaping a discovery deposition. This can decrease coaching, objections and interruptions by opposing counsel. The witness may be more “straightforward” about revealing information. The videotape can capture the looks and gazes at your opponent for help. These tapes can be extremely effective in impeaching witnesses.

Take a videotape of a strong witness who would make a good appearance. This could enhance settlement. For example, videotape may be taken of the Defendant’s deposition or the Plaintiff’s treating physician. Excerpts from this deposition can be presented to the Defendant’s insurance carrier with other information in a video settlement brochure. Portions might be played at mediation.

Video depositions can be an effective tool in modern day litigation. Like other tools, it should be used after the lawyer has thoroughly assessed all the facts and determined that they will enhance his or her case.

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