Deposition Scheduling of Opposing Clients or Witnesses
Scheduling of depositions opposing counsel's clients/witnesses is a common procedure that we want to make sure we do exceptionally well. So we have to document the steps, and make sure to refine them as we learn more about how to do this common procedure more effectively.
In his book, The Power of a System, John Fisher admonishes that: “It is very important to schedule the depositions before the deadline set forth in the preliminary conference stipulation and order” See pgs.117-130.
1Contact Opposing Counsel's Team
- Contact the Opposing counsel's team (speak to their deposition scheduler or the immediate assistant to the defense council on file for matter) and ask to obtain a date of when their clients/witnesses would be available to be deposed.
- Be sure to end the call with a date and time at least tentatively scheduled, get the person’s name and email
- Depositions should not be scheduled later then 10am for all parties, because it can take up to 8 hours.
2Follow up with an email
- Follow up with an email to the effects of “Per our conversation earlier we have confirmed the deposition of (party (s) name) in the (–matter).
3Calendar the scheduled date
- Enter the date and time in calendar. Notify paralegal in order to send confirmation letter.
4Notify court reporter/videographer of data
- Contact the appropriate videographer and stenographer or the court reporting firm, providing them with the confirmed deposition details.
- Always obtain an email confirmation in order to file into our practice management system, and to forward to all necessary parties