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Video depositions are the most popular option for deposing a witness these days. The ability to convey body language and tone to the jury is a major reason why attorneys videotape their legal depositions. Of course, something as simple as an unprofessional wardrobe or fidgety behavior on the part of your client may be enough to break your case. That’s why it’s vital to prepare your client before hitting “record” on the camera. This checklist has everything you need to get your client ready for their first deposition.

Direct Your Client on How to Appear

  • Dress comfortably and professionally.
  • Wear solid colors with no bold patterns.
  • Skip the distracting tie or flashy jewelry.

Explain the Proper Body Language

  • Get comfortable. If you want to remove your jacket, do so before the deposition starts.
  • Sit up straight and keep your hands on the table.
  • Don’t fidget, cross your arms in a defensive position, or make excessive hand gestures.
  • Be cognizant of your facial expressions.
  • Maintain eye contact with the attorney questioning you. Refrain from averting your gaze, rolling your eyes, or darting your eyes around the room.
  • Strive to appear engaged, interested, relaxed, and polite.

Address the Questioning Process

  • Be informed of the anticipated lines of questioning.
  • Know what objections your attorney plans to raise.
  • Feel free to ask the attorney to rephrase a question if you don’t understand.

Give Response Tips

  • Never volunteer information. Only answer what is asked of you.
  • Wait for the attorney to finish speaking before you provide an answer.
  • Avoid long pauses in your responses.
  • Don’t argue with the attorney posing questions.
  • Don’t make up answers if you’re not sure. “I don’t know” and “I don’t recall” are appropriate responses.
  • Never allow the questioning attorney to provoke a display of anger.
  • Avoid jokes, sarcasm, and making light of the situation.

Provide Other Important Reminders

  • Turn off your cell phone.
  • Understand that the opposing counsel could use your video deposition against you in court.
  • Know that you can object to a video deposition if you wish.

Bonus Tips

In addition to the above instructions for your client, remember to do the following yourself:

  • Schedule your deposition with plenty of time to prepare.
  • Arrive early on deposition day. This allows time to answer your client’s questions and warm them up with small talk.
  • Show your client some examples of other depositions, both good and bad, to help them understand the right way to behave.
  • Conduct a mock deposition to give your client a feel of what to expect.

At Talty Court Reporters, we utilize the latest technology to deliver the very best results in your legal case. Turn to us for top-quality video and audio conferencing, remote depositions, court reporting, transcribing services, and much more. For additional information about our services or to request a cost estimate, please contact us today.


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