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

by: Prince, Glover & Hayes Wednesday, June 2nd, 2010

Types of Depositons

Deposition by Telephone

Depositions can be taken via telephone. This typically occurs when the lawyer needs information from less significant witnesses or when there is a need to control cost.

Advantage of a telephone deposition

A telephone deposition is less expensive and saves the lawyer travel time.

Disadvantage of a telephone deposition

The great disadvantage of a telephone deposition is the inability to observe the witness’ appearance, dress, manner, expressions, style, and body language.

Arrangements for a telephone deposition
After it has been confirmed that the deposition will be conducted by telephone, the following arrangements should be made:

1. Determine which lawyers and parties will participate in the deposition. Will they attend in person as part of the telephone conference, or remain at a third site such as their office or home? Will a multiparty long distance connection of the proceeding be required?

2.Make sure that the locations for the conference call are equipped with speakerphones and fax facilities, if appropriate, and obtain confirmation of all numbers and locations.

3. Prior to the deposition, obtain an agreement on the pre-marking of exhibits and any procedures necessary for the introduction of unmarked exhibits via fax or other means.

4. Arrange for a court reporter and a long distance company or operator well in advance of the deposition. A modern telephone conferencing system will allow you to do this deposition at less cost. (One example is

5. Make sure that all arrangements are confirmed in writing. This is absolutely necessary to make sure everything runs smoothly.


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