International Depositions by Written Questions

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Image by idonotwanttobeyourlawyer.comConducting depositions abroad by written questions can save significant time and money.  It is helpful to submit the written questions and, if present, opposing counsel’s objections, prior to the deposition date so the court reporter can properly prepare.  While the court reporter is often responsible for reading the questions and objections, if your depositions are videotaped, you may want to consider having the videographer read the questions so that the reporter  can focus on taking down the record.  This will keep the deposition moving along at a reasonable pace.

Any exhibits to be included in your deposition are pre-printed, bound, etc., to your specifications before the deposition starts, and the videographer can present the exhibits as appropriate during the proceedings.  At the conclusion of the deposition, you may choose to have your documents shipped to you or, if preferred, the court reporter and videographer team can arrange to have them picked up and shredded at a secure facility.

Your court reporting team can also coordinate details on the ground, serving as the point of contact with the hotel, for example, to go over details such as catering needs for your deposition, access to the meeting room, etc.,  effectively assuming concierge duties as well, taking an additional task off your hands as you prepare your client’s case.

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