Your International Deposition Checklist (Updated 2017)

By Suzanne Quinson

This time of year, lists are very popular. Everyone has their gift list, their holiday chore list and, of course, a grocery list for planned festivities. And don’t forget Santa’s list, which he has diligently compiled throughout the year and checked twice, so I hear. So what better time than now to provide the checklist to use for your international depositions coming up in the new year? I personally love a good list and relish checking off the items once a task is completed.

For paralegals and their attorneys, a checklist for international depositions is an especially useful tool, as for many, international depositions are not an everyday occurrence. The checklist helps keep the scheduling process clear and on track from the very beginning. There are considerations involved in scheduling depositions overseas that don’t come into play if the deponent is just down the hall.

Travel may mean visa requirements, and certainly take a look at that passport to make sure it is current per your destination’s passport validity guidelines! Different countries have their own rules concerning depositions, and in some cases, these rules add to the scheduling timeframe. When using a global court reporting agency and the below checklist, you can schedule your international depositions with confidence and peace of mind.

First Things First:

1. Can you take a deposition in the country in question?  Verify local laws governing depositions before doing anything else.
   • For additional assistance, ask your global reporting agency (e.g., scheduling in Japan or other more complex locations)
2. Verify the code of civil procedure for your own state – most authorize the taking of depositions in a foreign country.
3. Check out those travel requirements!
   • Is a visa required?  If so, how long is the process for obtaining one?
   • Is your passport validity date sufficient for your travel destination?
   • Are any vaccinations required?
4. Determine if the witness is a willing witness.
5. Discuss the administration of the oath and come to an agreement with all involved parties.

Now to Schedule:

1. What court reporting services do you need?
   • U.S. – trained court reporter?
   • U.S. – trained videographer?
   • Additional assistance from the on-the-ground reporting team?
     • Printing?
     • Shredding?
2. Interpreter?
   • Dialect?
   • Any special experience preferred?  (e.g., highly technical I.P. matters)
3. Identify your preferred location.
   • Number of attendees?
   • Refreshments included?
   • Printing capabilities on site?
   • Conference room in a hotel or business center?
   • Conference room in a law office?
   • U.S. Embassy or Consulate?  – This will be determined by the very first step in the checklist, verifying local laws – e.g., depositions in Japan are permitted only on Embassy/Consulate grounds.
4. Decide if videoconferencing is required*
   • Location in host country reserved?
   • Location in U.S. reserved?
   • Location of reporter, videographer, and/or interpreter?
     *Please note: videoconferencing is not permitted at the U.S. Embassy or Consulate in Japan.
5. Choose and lock in deposition dates
   • Start time
   • End time

Plan your Travel:

1. Visa taken care of, if applicable?
2. Passport good to go?
3. Flight reserved?
4. Hotel accommodations made?
5. Car service arranged?

Reporting Logistics:

1. Protective Order, if any, sent to the reporting agency?
2. Special services needed?
   • Number of realtime connections needed
   • Turnaround time
   • Distribution list(s) for Rough Drafts and Finals
3. Notice of Deposition sent (to all Counsel and the witness as well)?
4. Reporter preparation materials sent?
   • Complaint and Answer;
   • Any previous transcript(s)
   • Court order
   • Patent(s), if applicable

With your checklist prepared, all you have to do is read it, ask your reporting agency for any additional clarifications or advice you need regarding the process, and delightedly cross off items or make your check marks, whichever method makes you feel more accomplished! You are now set to march into 2018 ready to take on depositions anywhere a case takes you!

Equally as helpful as the above checklist is the global court reporting agency, which has popped up in the list more than once. They are the experts who have covered proceedings around the world, and have reporters, videographers, and interpreters living around the world with the experience you need.

Also worth a mention is the fact that because their reporting professionals live throughout the world, travel costs are often greatly reduced, or even non-existent. They can reserve conference rooms overseas for you, as well as provide recommendations for accommodations for your team traveling abroad. They can even suggest the best dining options in town!

For more information on scheduling depositions anywhere in the world, contact Planet Depos International Scheduling Department at 888.433.3767 or international@planetdepos.com.