It is not necessary for your client to wear a suit and tie; business casual is appropriate Men should wear collared shirts and women should wear a nice blouse. For interviews, only the upper body will be in the shot, so don't stress over pants or shoes, since they will not be seen.

AVOID:

• White, black and red do not read well on camera and can be draining to one's skin tone. White and red can also make one look heavier on camera.
• Loud patterns, fine stripes, checks, houndstooth and plaids are also hard for the camera to read properly and can be very distracting. Don't wear them.
• Dangly earrings, bracelets and shiny jewelry because they create distraction and glare.

DO WEAR:

• Solids in blues, greens, roses, lavenders and peach are the best color choices.
• A collar or a V-neck is preferable to a turtleneck. Make sure clothes fit, are clean and are ironed. The lighting will make the room hot, so don't wear a heavy sweater.
• Have a couple of choices ready in case the videographer thinks one look could be better. Do not be insulted if your videographer makes you change. She is helping you look your best, which in turn will help bring about the best results possible.

If you are shooting Day in the Life activities, plan on about 4-6 hours of shooting time. Your videographer will need time to scope out the location and decide where to set things up. Lighting will need to be adjusted, sometimes furniture has to be rearranged.

Interviews can take anywhere from 1½ - 3 hours per person, depending upon each person's relationship with the client. Children and experts will take less time to shoot, whereas the plaintiff and his or her immediate caregiver will take much longer. Never schedule more than three interviews per day.

Do your clients live on a busy street? Near a bus stop? Train tracks? A fire station? An airfield? Next to a construction site? Next door to or downstairs from noisy neighbors? Near loud barking dogs? Make sure to ask them well in advance of the project.

If the answer is "yes" to any of these questions, try to find an alternate location. When shooting, sound quality is of the utmost importance. Frequent interruptions will prolong the shoot and cause unwanted distraction.

Young children might not understand their parent is busy or could get upset if their parent can't attend to their immediate needs. Find out if a play date or daycare can be arranged. You can also arrange the shoot to take place when the kids are in school.

Pets can occasionally cause disruptions. Most times they are fine, but if they are prone to barking or whining, have a quiet place they can retreat to.

When deciding who should be interviewed, ask your client who has been a constant in their life before the incident and is now part of their support system as they navigate life's new challenges.

They will, most likely, suggest their spouse, children, parents, siblings and close friends. Consider interviewing a former coworker or boss who will speak to your client's work ethic and lost earning potential. Sometimes teachers or other school officials can describe changes observed in your client's children. Venturing outside the realm of family members, select people who can be somewhat protective of your client, as this helps to add a different perspective on how far-reaching the damages are.

Expert witnesses add impact to your presentation and validate the concerns for your client. Medical experts can describe your client's condition, what their current limitations have become and what they face as far as future surgeries and therapies. Life care planners and economists can discuss what needs your client will have in terms of home modifications, medical equipment/supplies, and services. Psychiatrists can describe the symptoms of misunderstood diagnoses, such as Post-Traumatic Stress Disorder, and how they apply to your client's current patterns of behavior. Expert interviews will support the testimonies of your interviewees and add credibility to their concerns.

In the end, you will want to get the list down to about 3-7 good candidates. If your case were to go to trial, who you would you call to the witness stand? Determine your interviewee list from that answer.

Yes!

Send your interviewees a list of discussion topics a few days before the shoot. This will help alleviate any anxieties they might have about what they will need to revisit emotionally. It will also give them a few days to recall memories and the chain of events. Do not worry that they will appear rehearsed. You are not giving them a script to recite. You're just letting them know what to expect and helping them be comfortable with this process.

Avoid generalities such as "Joe was a hard working guy." Get the interviewees to tell a specific story that exemplifies what made Joe so motivated. I always recommend asking your interviewees to be ready with two to three favorite memories of the person they will be discussing. These stories can be funny, touching or even mischievous. These are the details that make your client likable and relatable.

Your client may find looking through photo albums helpful to prod their memory and provide you with photos that can be edited into the piece during post-production.

Day in the Life videos are usually shot for catastrophic injury cases to give your jury a glimpse of what your client's typical daily routine consists of. These videos are subject to the rules of evidence, so it is important to discuss admissibility concerns with your video company. Rarely are these issues a concern as long as the activities are documented fairly and accurately and without prejudice.

Talk with your client to determine which activities comprise their daily routine. Depending upon your client's affliction, these activities will vary. Common examples include: getting out of bed; grooming; transfers to commodes, shower chairs and wheelchairs; getting dressed; preparing and eating a meal; and performing other activities of daily living.

Be sure to also include any therapies and modifications made to the home or vehicles.

If shooting any activities that include a PCA or therapists, make sure to get permission from their agency that their employee may appear on camera. Be sure to explain that they will not be speaking on camera. They will just be interacting with your client as if a camera wasn't there. They do not need to narrate their activities, because they, or your client, will narrate live at trial.

Avoid gilding the lily. This will make your video inadmissible and ruin the credibility of your case. Stick with your client's daily routine and veer away from showing overly dramatic demonstrations of a task that is impossible for your client to complete.

No!

It is unnecessary to allow a jury and an entire courtroom to see your client in such a vulnerable state. You never know who you may offend and alienate by doing so.

I recommend having your client wear, at the very least, a t-shirt/tank top and shorts before showing the assistance needed in getting dressed. If someone needs help getting pants on and buttoning a shirt, trust that the viewers will understand that underwear and diapers will also need assistance.

Getting onto shower chairs and commodes can be done fully dressed.

Your client has suffered a devastating loss and deserves to be treated with dignity. There is no added value to showing them in a state that you yourself would not want to be seen.

Watch some episodes of "60 Minutes", "20/20" or "Dateline" to get an idea of the pacing and the style of the video.

The only difference will be that your interview questions will NOT be heard. The story will be told strictly through the interviewees' voices. Because of that, they will need to respond to your questions in a way that we will know what was asked. This is why "Yes" or "No" answer questions won't work for these purposes. You need to have a conversation with the interviewee rather than question them. Questions should start with "Tell me about..." rather than "Who?" "What?" or "Where?"

Ask your clients to get together some pertinent photos and home video footage of life pre-incident that can be added in during post-production. If the case involves an accident, find out if any reports were aired on any local news stations and get a DVD copy of that footage. Are there accident scene photos? Find out if any photos were taken of your client in the hospital. These can be added to the final video to add impact.

Some video companies will suggest having a professional narration added to the final video. That use varies around the country. States such as California and New York tend to use that practice more than in New England. Determine who your audience will be and if that would be necessary. Since most videos portray the damages, rather than the liability, you will probably decide that your client and other interviewees do a great job telling their story without a professional narrator.

I've been asked about adding music to the final presentation. I would strongly discourage you from going that route. You run the risk of making your viewer feel manipulated by schmaltzy tactics. This, in turn, could undermine the credibility of the rest of the video and ruin chances for settlement at mediation. Chances are, if you are going through the effort of producing a mediation presentation, you probably have a very compelling case to begin with.

YES!

Remember this before giving any suggestions or directions while tape is rolling. Make sure to say "Stop tape!" before having any discussions with your client about the case, timeline, etc.

Before shooting scenes for Day in the Life videos, which is subject to the rules of evidence, have your client explain, to the best of their ability, what steps are involved in whatever activity they are about to engage in. This will allow the camera person to determine which angles to shoot from to avoid re-takes.

Be aware that your camera person and/or editor can be deposed at trial.