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I. Prepare the Reporter
A. Schedule the Deposition
If you expect the deposition to continue after 5:00pm, let
the agency know in advance.
B. Notify of Any Special Requests
- Video
- Interpreter
- Expedited Transcript Delivery
- Real-Time Hook-up
- Same-Day Rough Draft
C. Prepare Documents for the Reporter's Review Prior to the
Deposition
- Your Business Card
- Case Caption
- Exhibits to be Marked in Advance
- Technical Terms/Names
II. Prepare the Witness
- Remind the witness to bring photo ID per
MA Exec. Order 455
- Caution the witness to wait until the examiner finishes
each question before answering. The reporter cannot
record two voices simultaneously.
III. Making a Clean Record
Read documents into the record slowly and deliberately, provide reporter a copy. Identify each exhibit on the record using Bates number, date, author, title, etc.
IV. On/Off the Record
Verbally indicate each time the reporter is to go off the record and on the record.
V. Comfort
- Provide appropriate chair
- Ten-minute breaks every 90 minutes
- Minimum 30-minute lunch break
- Maximum 7-hour workday
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