1) Hold the Deposition at the Home or Office of the Deponent
	We are dealing with real people, not actors. Your witness will feel more comfortable in his/her own environment, won't be frazzled from driving through the Big Dig, looking for parking, etc.

2) Discuss Wardrobe Options with your Witness
	Ask your witness to dress as if they were going to appear in court. Jackets and ties for men and subdued blouses and jackets for women are a must! If your witness is a doctor, have them wear a white coat. It lends credibility. Make sure their hair is combed, ties are straight, make-up is not smeared and teeth are brushed. No Reds, dizzying stripes/prints or shiny jewelry.

3) Make Sure the Background is Pleasing and not Distracting
	Make sure your witness' desk is neat and not cluttered. Try to have diplomas hanging in the background. Make sure there are not any mirrors or glaring picture frames that can reflect light into the camera. Do not sit the witness in front of a window.

4) Be Aware of Any Nervous Habits your Witness May have
	Nail biting, finger tapping, chair rocking and other fidgeting can be very distracting. Try to come up with a signal that you can give your witness when any of these behaviors arise. Keep a glass of water next to your client to prevent dry mouth and coughing.

5) Sit Next to the Camera Lens
	If you sit near the camera, the jury will see more of the witness' face when you speak to them. If you sit right next to them, they will be turned toward you and the jury will see their profile. You can tell the witness to speak to the camera, but five minutes into the deposition,they will forget all about that.

6) Keep the Direct Exam SHORT!
	The average TV sitcom is (23) minutes long and a lot can happen in that amount of time. Try to keep your exam within that time frame. Go longer and you start to lose the viewer's attention. Let the other side put them to sleep with repetitious questions and hypothetical situations.

7) Illustrate the Testimony with Photos, Charts or Models
	Have your doctor use a plastic model of the spine to show exactly where damage has occurred. Combine that with a chart of the entire human skeleton to give the viewer perspective. Show X- rays or MRIs. If devices such as rods, screws, ball and sockets were implanted into your client during surgery, have an example on camera to give the jury a better understanding of your client's ordeal.

8) Make Sure to Take a Lunch Break if it's an all Day Deposition

Don't skip lunch or continue to question while eating. Take a thirty-sixty minute break to eat and relax. Not doing so can cause tempers to flare or hostility to set in. Eating while deposing adds the further distraction of chewing sounds, soda cans opening, and potato chip bags rustling. Take the time out. It will give you a chance to refresh, touch base with your witness and the stenographer a chance to rest.

9) Make Sure you can Understand your Witness when They Speak

Yes, this may sound funny or obvious, but if you can't understand your witness, no miracle of technology- barring subtitles- can change that. If your witness has a heavy accent or is a "Mumbler", encourage them to speak up and to speak slowly. If your client wears false teeth, make sure they are in that day because it makes a huge difference! If all else fails, repeat the witness' answers. This will help the jury and the stenographer.

10) Have the Videographer Set-Up the Exhibit Shots Before Shooting
	This will help in having everything in proper position, proper lighting, etc. before shooting. This way there aren't awkward moments during the deposition to distract the viewer.