Thought for the day: Where do YOU sit at a depo?

[Deborah M.]

I am in Los Angeles, have been reporting for almost 20 years, and I was always taught and have always tried to sit at the head of the table, with the witness on one side of me and the questioning atty on the other side, directly across from the witness. Then the wit's atty sits on the other side of him or her. No one ever questions it and almost always will seat themselves that way if I'm not there first (which is rare). Anyway, I did a depo the other day for two attys from Texas and they were expecting the witness to sit at the head of the table, it seemed. I've never even thought of doing it any other way except once in a while with a video where due to the placement of the table, they need the wit at the head of the table, in which I case I sit on one side of the wit and the questioning atty sits on my other side.

What is the traditional setup where you live? Is it different? I'm just very curious to see what is the custom, if there is one, in other places.

[Reid Bryce Robbins]

I use your setup. I have been reporting about 30 years. About a month ago, one of the attorneys said to me, "I have never seen a deposition set up this way!" I said to him, "I guess you haven't been an attorney as long as I have been a court reporter. Glad to change it if you prefer; but this is the normal way I have been doing it."

[Katy Cuellar]

I have always sat at the head of the table. I insist upon it. There was, however, one occasion in my entire career where I could not sit at the head of the table, and that involved a Muslim man who insisted I not be allowed to sit in "the place of honor."

[Deborah M.]

Oh, boy! And how did the rest of the depo go? I can just imagine.

[Quyen]

I always sit at the head of the table. I'm usually the first one to arrive that the depo, so I'm all set up by the time anyone shows up. They don't even get a chance to tell me where to sit. Most of the time, the attorneys would ask me where I want the witness *grin*. But I'm with Kelli. I don't like to be bullied around and told how/where to do my job. I do what I have to do to make MY job easier for ME, and if the attorney doesn't like it . . . well, tough.

Recently, I did a depo at the Marriott. The conference room was huuuuuge, which makes it a bit difficult to hear. On top of that, there was some noise right outside the door, making it nearly impossible to hear a thing. Of course, I'm SURE it would have killed the questioning attorney to speak up.

After asking him several times for him to speak up and after straining to hear all morning, I decided I'd had enough. I opened the door, looked all around for where that noise was coming from. I look up, and low and behold, there was a GIANORMOUS air-conditioning unit blasting right outside directly above the door. That thing was so big, it would have frozen Haites over. I mean, it was probably the AC unit for the entire hotel, I tell you.

I went back in and told the attorneys that we were either going to move to another room or we're getting that AC shut off. Moving to another room would have been no small task given the number of people present and a teleconference. I was making an executive decision. Yes, I TOLD. I didn't ASK. I called the front desk. The danged AC was shut off in less than 10 minutes. Not one peep of protest from any of the attorneys. :)

[Deborah M.]

Wow, how the heck can she hear anything? I always yell at the TV when they show the reporter in some far corner somewhere.

[Mary Ann Payonk]

Hi, Deborah. I don't think there's a traditional setup. When I worked in Richmond, Va. (20 years) I was used to setting up with the witness at the end of the table, me sitting in the first chair to the side, and the conducting atty right behind me (so that when the witness answered, he was speaking kind of through me to the atty sitting behind). Also, that way, the defending atty could sit close to their witness in case they wanted to confer (or kick under the table ...) Moving to DC, and with 99% of the work I do with videography, it's remained the same setup. Although I recently did a set of deps with videographer where the atty insisted on putting ME at the end and wanted to sit directly across the table from the witness (for DIRECT eye contact ... and perhaps intimidation factor), having the videographer set up his equipment right over the conducting atty's shoulder for a straight-on shot. That was very unusual.

M.A.

[Deborah M.]

Well, if the atty is BEHIND you, does that mean they're not actually at the table? Don't they need the table to write on? I'd say we do it the direct eye contact way 99.6% of the time! All the attys I work with always want to look right at the witness. Interesting differences regionally.