I thought there was a thread about this but couldn't find it.

It seems all my jobs now have 40 plus exhibits.  Jeez, it takes a lot of time to type in the descriptions for these, especially with all the emails.  Can you get away with just saying:

"Email dated ______"   Or "Email chain dated__________" instead of who it's to and from?

How short can we get away with our descriptions.  Because I had to index 60 exhibits on a job last week and it was a PITA!   My index was 10 pages long.

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Yes, a flathead screwdriver should.  Might have to use a little pressure.

Also, those small screwdriver sets used on computers and eyeglasses and such work great.  But a thin flathead screwdriver should work.

Oh, yes!  I was thinking of a -- what's it called?   The round thing that you use for certain whosies.  Oh, yeah, a skinny flathead screwdriver, that is the ticket. Thank you.  Will procure one of those soon!

There is a little tool out there to remove heavy-duty staples.  It's kind of like a teeny crowbar.  Very simple and easy to use.

I have no problem with putting no description at all, if I am pressed for time.

Then sometimes I will put a ridiculous amount of information, including page count.

Depends on mood, too.

I tend to use the description that the attorney uses in the transcript and simply copy it.  If it was a good enough description in the transcript in my opinion means it's a good enough description for the index.

The problem is a lot of attorneys don't even describe the exhibits or the Bates numbers, and that's where it becomes time consuming.  I copy and paste descriptions too when they say them.  

Number of years I haven't put exhibit descriptions in deposition transcripts:  5

Number of complaints or comments I've gotten about it:  0

M.A.

Mary Ann,

Then how does your index look?  Exhibit No.       Description             Identified

No description column?

I'd love to do that.

Most of the reporting firms I work for give me a transcript sample that includes how they want their exhibit index to look, and I usually try to follow that.  

I have had one or two attorneys complain to me that sometimes the exhibit indexes that reporters create are so brief as to be completely useless when the attorney is looking to the exhibit index to refresh his memory on a document that he is searching for -- in other words, using the index as an actual index.  

My preference is to do a single-spaced description of each exhibit that takes up one to three lines and includes the To and From and Date and Bates Numbers and a very brief description of the Subject.  I like to spend some quality time with the exhibits, creating a job word list and becoming familiar with the terminology and the case.  That also helps me to understand some of what I've written as I then begin to edit.  

It does take a considerable amount of time when there are a lot of exhibits, but I think that's just part of the job, like the time it takes to create the opening and closing pages.  On the bright side, the more exhibits there are, the more spellings I can find, and the more accurate my transcript will be :-)

On another note, do you think it's reasonable to ask the reporter to print 100+ pages of exhibits at $0.25/page? And bring an additional LAPTOP to videoconference the witness so the taking attorneys can appear and TAKE the depo by video?

Printing 100 pages for $25 is not a bad deal at all.  I'd do it.  As far as the laptop, my Skype surcharge is .50/page for each person.    Makes it worth our while.

Over the years I have had several requests for dates so I start every description with 5/2/13 letter from Smith to Jones and leave it at that.

if it's a chain, I start with the earlier one and write "chain" in there - it takes too long to do a very big description.  we can't get away in Texas with all the extra  spaces and 24 lines that I have seen recently.  I actually saw "Whereupon Smith Exhibit 26 was marked for identification." followed immediately by "Exhibit was tendered to the witness."  That's like 5 lines per exhibit.    Personally I HATE whereupon.  It's antiquated terminology but hey....to each his own I believe they say.

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