Remote depositions necessitated by the 2020 Covid Pandemic gave birth to an unexpectedly effective deposition technique that I call the “three-screen method.”
Under this method, the examining attorney sits before three different screens: (1) a center screen through which the deponent is examined; (2) a screen positioned high and to the right of the center screen, on which a deposition outline or notes are readily seen without the seen to look down; and (3) a screen positioned high and to the left of the center screen, on which the questions, answers, objections, and discussions are automatically transcribed by voice recognition software in real time, for immediate review of what the record will ultimately look like.
When used correctly, the three-screen method yields a clean, user-friendly official transcript containing no read-back questions by the reporter. Also, because the witness’s testimony can be viewed in real time at the deposition, there are no later surprises by answers that are not as wiggle-free as might have otherwise been perceived at the time.
By, Anonymous
B.A., J.D. University of San Diego
Author’s web address withheld by request
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