b'Page 6FBA/OC Remote Depositions in the Timeplatformthatwas moreintuitiveandeasier of COVID-19to use with a wider audience more beneficial, particularly when taking depositions.By Stephanie Phan and Sheila Chen* 2. Look for Opportunities to Streamline Efficiencies.Itmaybehelpfultoconfer withopposingcounselandseeifthereis COVID-19haschangedtheagreementovertheplatform.Ifso,this waywelitigatecasesinwould allow you to avoid having to learn and 2020.Withcourtclosuresswitch between different platforms during the andsocialdistancing,wecourse of discovery. haveallhadtoreimagine thewayinwhichweprac- 3.FinalizeExhibitsEarlytoSaveTime ticeaslawyers,whichinDuring Depositions.Withremotedeposi-theseunprecedentedtimestions, we have found that we needed to final-includeslitigatingandde- ize the exhibits much earlier than we did with posingwitnessesfromourin-person depositions. Somewitnesseshave homeoffices.Asremotefound it difficult to review lengthy documents depositionshavebecomeon a screen without the ability to turn pages thenewnormalinmanyin a paper copy.One potential solution is to jurisdictions,divinghead- provide a paper copy of lengthy documents to firstintotheseunchartedthewitnesssothatthewitnesscouldeasily territoriesintheearlyreview the exhibits when they were identified months of the COVID-19 shutdown presentedatthedeposition.Whentakingthedeposi-uswiththeuniqueopportunitytodevelopation, this can assist with the flow of question-new skillset amidst a pandemic.For all of theingandincreasethepacesincethereisan planners out there, we have compiled a list ofinherent lag built into the remote deposition eight tips that we learned from our last eightprocess. remote depositions.4. Bring Additional Help.Ifpossible,itcan 1.PicktheDepositionTechnologyYouoften be helpful to have a second chair attor-AreMostComfortableWith.Itisim- ney or paralegal in the depositions to help up-portant to select and become familiar with theload and publish the documents during ques-deposition technology before the remote depo- tioning.Entering an exhibit into the record is sitionoccurs.Thereseemstobetwomainnot as seamless as with in-person depositions, typesofplatforms:thosethatrunonZoomasdocumentsmaytakelongertolocateon technology(whicharefairlycommon)andyourcomputerandupload.Havingacol-those that use a proprietary based technologyleague in the deposition with you allows the with many bells and whistles.Things we in- nextexhibittobeuploadedwhileyouwork quiredaboutwhendecidingbetweenplat- through the questioning of the prior exhibit.formsincludetheirdocumenthandlingfea- This allows you to listen to the witnesses an-tures, additional security features, and wheth- swers without also having to juggle the depo-er technical support services would be provid- sitiontechnology.Manyremotedeposition ed during the deposition.We found that the(Continued on page 7)'