Tag Archives: deposition

Five Best Practices

Video Depositions: Five Best Practices

Video Depositions:  Five Best Practices Every Paralegal Should Know.

In this blog we will be talking about video deposition’s five best practices. When preparations are in order for an upcoming trial, there may be a witness or witnesses that cannot attend in the courtroom itself. This is where you would normally call upon your court reporter to set up a video deposition. There are many advantages of having the ability to not just read the testimony but to gain a visual of the witness as he\she answers each question under oath.

Ask that all other electronic devices be turned off.  To ensure the clearest sound and best playback for the record, ask that all cell phones and unnecessary technology be turned off. Also keep any paperwork from being in the way of microphones. Believe it or not, shuffling paperwork can cause interference to the recording.

Reserve enough space for everyone to be comfortable. When booking a room for a Video deposition, keep in mind that you will need to let your court reporter know how many people will be in attendance outside of the attorney, the videographer, the court reporter and the witness. This will be a good time to address any special needs of anyone attending also.  Be sure to state special needs a couple days before to ensure everything goes smoothly and as planned.

 Early access for the videographer. At least one hour is the common standard for the videographer to set up his equipment and run all necessary tests, adjust lighting and to troubleshoot any technical issues that may arise beforehand.

Make it clear when you’re off the record.  Microphones are extremely sensitive.  Always remember that until clearly instructed that it is off the record, the video and audio are being captured. Another important factor in conducting great video depositions is to instruct everyone to speak one at a time. Try giving 2-3 seconds after being asked a question to give your response. This will also help you keep your cool and think before you speak.

Keep the space being recorded clean and free of clutter. You want to be certain that all things obstructing the clear view of the witness be removed. The jury’s attention is to remain on the testimony and not on distracting objects that do not belong there in the first place.

Video depositions are a very useful tool to save time and money.


Avoid Bad Q&A

Depositions : Avoiding bad Q&A

This blog is about recognizing and avoiding bad questions and answers during a deposition or trial. Assisting your client in refreshing their memory regarding facts pertinent to the case is important but that’s just the start of what is in store for the preparation of your witness for upcoming deposition or trial.  You also need to prepare your client for problem areas of questioning.  In this blog we have listed some problem questions and how to react and answer them properly during the course of a deposition of your client:

Compound Questions

Compound questions, which incorporate two questions in one, such as, “Do you smoke marijuana every day or just once a week,”,  the first question in this statement is “Do you smoke marijuana”,  and if yes, is it every day or just once a week , this form of  questioning is very deceptive and dangerous because a yes- or-no answer can be interpreted as an affirmative response to the underlying predicate.

Questions in Absolute Terms

Whenever an attorney uses such terms as, “Do you always” or, “Have you never,” they are attempting to lock your client into absolute terms. There is nothing wrong with being absolutely sure, you just want to make sure that that is in fact the case.


There is nothing that more quickly undermines a claim or gives rise to the all-popular defense mantra of “secondary gain” than needless exaggeration.


Stay factual!  Do not guess and do not speculate.  You do not have to have an answer to every question, and that is okay.  You are only human.

“Would It Be Fair to Say…”

Anytime a witness hears a question prefaced with such a line, they should make sure they in fact agree with the proposition set forth in the question, as this is often unfair to the witness.

For more information on this topic we recommend reading The five worst things to do during cross-examination.

Looking for the very best in Phoenix court reporters ? Call us today at 602-230-2499.



Out of State Depositions

3 Steps to Help You Prepare for The Out of State Deposition

official court reporters vs freelanceThe witness that is critical to your client’s case will not always be in your state. When this happens, there are several legal and other preparatory steps that must be taken to depose the witness. In this blog, we explore the necessary steps to prepare for an out of state deposition.

As a paralegal, your role, under the supervision of your assigned attorney, is to ensure that the necessary steps are taken to secure the witness for an out of state deposition.

Know the State Laws

Each state has different rules and laws as it relates to depositions and the process required to compel a witness that is within their jurisdiction. You must ascertain the specific county in which the witness resides and determine the procedural rules that must be followed to depose the witness.

A quick way to make sure that your law firm is following all of the procedural requirements of your witness’ home state is to contact the clerk of the court. The clerk can provide accurate information on how to go about deposing the witness in their jurisdiction, along with regulations relating to serving a subpoena.

Secure Your Witness

It’s always easier when the witness is a willing participant. However, this isn’t always the case. It is important to note that sometimes even consenting witnesses will change their minds and depending on the value they add to your case; it may be best to secure your witness’ presence with a subpoena.

This process of using a subpoena to secure your witness varies from state to state. So, it’s important that you understand the overall process and. Some states require a commission or letters of rogatory as part of the procedure involved in securing a witness. You may also want to consider hiring a law firm from that state in addition to obtaining information from the clerk of court.

Every aspect of your client’s case is time sensitive so obtaining and serving the subpoena should be top on your out of state deposition to do list. A witness who does not turn up for the deposition can result not only in out of pocket expenditure for your attorney, but your client may also have to pay the opposing side’s expense.

Plan Ahead

All legal proceedings require at least some preparation. However, when your witness is out of state, more planning is required to make sure that everything is in place to facilitate the deposition. In addition to adhering to the laws and regulations of that particular state, making the necessary applications in your state is also important to ensure that you are on the right path.

Further, since time is of the essence, it’s important to make sure that you meet specific deadlines. With an out of state deposition on hand, there are greater chances of delays. As a paralegal, you will need to factor in such issues and plan accordingly to ensure that there are no eventualities that will cause your client more money.

Planning ahead will also include preparation for the actual deposition day. With an out of state deposition, there is no running back to the office to get a file or document that was left behind. It’s vital that your attorney be equipped with all that is required to carry out the deposition in another state.

There are several logistical considerations involved in pursuing an out of state deposition. Once the preparatory legal filing and serving work is complete, both you and your attorney can focus on the general preparation that is required for a deposition.

Preparing Your Witness for a Deposition

deposition summary basics importanceAs a paralegal, your role in the deposition process is critical to the overall success of each case. In addition to helping the attorney prepare the claim, you’re also responsible for preparing the witness. Whether the witness is your client or a support witness for your case, thorough preparation can make a big difference on deposition day.

When prepping a witness for deposition, you should always work under the guidance of your attorney. However, there are a few things that you still should know.

Explaining the Deposition Process

Most witnesses are new to the world of legal litigation. Whether the witness is the average deponent or an expert, providing evidence can be overwhelming for anyone doing so for the first time. Your role is to explain the deposition process in a straightforward manner, and in doing so, you might be able to remove any anxiety on the witness’ part.

The information you provide should include:

  • An explanation of a deposition.
  • How a deposition fits into the overall legal system?
  • What are the possible outcomes of a deposition?
  • How will the outcome affect the case on a whole?
  • What is the role of the witnesses?
  • The importance of giving evidence at a deposition.

In your explanation, you’ll also want to allow room for questions. It might also prove helpful to prepare a general document or brochure; explaining the deposition process.

Answering Questions

Some witnesses are uncomfortable testifying in front of the other parties. This can create a great deal of anxiety, especially if the witness is attending a deposition for the first time. Whatever the nature of the evidence, there are several items that you’ll want to share with your witness, before they begin answering questions. Here are a few of them.

  • Listen to the Questions – It is vital that you impress upon your witness, that they listen carefully to each question. Explain to your witness that their answer is being recorded, and so it is important to ensure that their answer is really the response to the question asked.
  • Answer the Question Being Asked – Sometimes witnesses can get sidetracked and offer more information than what is necessary. Since this can complicate the case, you’ll want to convey the importance of only answering what they’re asked, as opposed to giving long winded answers that aren’t relevant to the question.
  • Seek Clarification – Occasionally, you may encounter witnesses who don’t understand something but refuse to ask questions. You can address this beforehand by assuring the witness that it is okay to seek clarification on anything that he may not understand.
  • Don’t Make Things Up – Your witness should enter the deposition room knowing that they don’t have to know the answer to every single question. So remember to encourage the witness to be truthful and accurate during the testimony.

Since a deposition is essentially a question and answer session, preparing the witness should be a top priority for you.

Advice on Physical Posture

While a witness’ physical appearance is not important to the recording of the evidence, it is a tool that attorneys sometimes use to determine the witness’ emotional state and how truthful he may seem. With this in mind, you may want to emphasize the value of maintaining an upright posture while being deposed.

  • Your witness should sit up straight in her chair and avoid looking rigid.
  • Where possible encourage your witness to avoid looking distressed, angry or frustrated.
  • Maintain eye contact with the person asking the questions.

Our bodies have the ability to transmit unintended information, so encourage your witness to practice projecting a calm demeanor.

Preparing the Witness via Mock Depositions

Under the direction of your attorney, you may choose to organize a mock deposition. In this scenario, your responsibility is to ensure that the witness is ready for the mock deposition. Additionally, you may want to confirm that your witness is familiar with the documents are part of her deposition.

Once you have completed the preparatory work, be sure to follow up with your witness and find out if they have questions or concerns. Another step you can take is to organize pre-deposition meetings with the attorney.

A well prepared witness is not only good for your case, but also ensures a smooth deposition process. Fortunately, as a paralegal, you have the opportunity to tilt the odds in your favor by preparing your witness for deposition. Hence, the saying, ‘a paralegal’s job is never done’.

Preparing for Deposition Day as a Legal Secretary or Paralegal

Court ReportersThe role of a legal secretary or paralegal professional is to use your legal training to assist the attorney with her legal work. In keeping with these overall roles and responsibilities, professional paralegals must be equipped with the necessary skills to help the attorney prepare cases for deposition. This piece will cover several specific steps that the legal secretary or paralegal can do prior to deposition day.

As the legal professional hired to represent the client, the attorney is in charge of the overall direction and focus of the case. Hence, it is important to have a meeting with the lead attorney handling the matter. In this meeting you’ll want to discuss any issues that are key to your client’s situation. So remember to gather as much information as you can to build upon the overall legal direction of the case. This type of information will inform your research and preparation.

While taking the initiative is good, it is also prudent to gather any research material deemed helpful to the case from the lead attorney. You will need to meet at the beginning and middle of the process to ensure that you are on the right path.

Research the Pertinent Legal Issues

The art of preparation begins with research. Following from your meeting with the attorney, as the paralegal, it is your responsibility to do the necessary research on the issues that concern the case. It is important to be as detailed as possible and compile your research in a way that is easy to read and accessible by the attorney.

Your research will include gathering relevant case law and research to substantiate your case, as well as getting information that could be used by your opponent. The latter will help the attorney to better formulate the case at deposition.

Finding previous testimonies by the witness or about the witness can provide the attorney with valuable information. The attorney for the case should be armed with all the available information on a witness and as the legal secretary you can help in gathering this intelligence.

Draft Potential Questions

The advantage of taking on research responsibilities as a paralegal is that your mind will be filled with questions. In assisting the attorney in his preparation, you can formulate potential questions for each witness. Depositions are about discovery and the best way to discover all you need to before trial, is to ask all the questions that will direct you to the right answers. Your proposed questions can be very valuable to a lawyer, as you may propose questions he or she may not have contemplated.

Prepare Necessary Documents and Exhibits

On deposition day, an attorney will want to focus on the task at hand. Your job is to make sure that documents and exhibits are obtained, copied, labeled and readily assessable. As the paralegal, the attorney will require your assistance in retrieving documents on deposition day. Hence, being organized and prepared is not only meant to help the attorney, but for your benefit as well.

The taking of depositions in a civil matter is very important. As a paralegal or legal secretary, the preparation work that you are required to do represents the well oiled machine of organization and research that is at the foundation of your client’s case.

The Paralegal’s Role in Handling Deposition Errata Sheets

video depositions law firmOver the years we’ve received a fair amount of questions regarding errata sheets. Usually, these questions tend to come from paralegals or legal secretaries that are involved in the ‘read and review’ process.

For anyone who has ever had questions about them, errata sheets give you and your client or witness the opportunity to identify and correct any mistakes that may exist in the transcript. The bottom line is that although court reporters are highly trained professionals, the reality is that as humans we sometimes make mistakes. The same can be said of the client or supporting witnesses.

However, since depositions make up a substantial portion of evidence at trial, it is important to make sure that the deposition transcript reflects an accurate account of the deponent. Here’s what you should know about managing the errata sheet process.

There is much work to be done when preparing your client, witness or case for depositions. After the deposition has taken place the read and review process begins. This gives you and your client or witness the opportunity to correct any errors that might have been made during the actual deposition. The corrections are recorded in the errata sheet.

Often during ‘read and review’, clients and witnesses feel it necessary to correct or add to what was said. However, it is important that they understand the review process is not about changing the substance of the deposition but ensuring accuracy. So how you manage the process of preparing and filing the deposition errata sheet matters; both for the client or witness, as well as for the potential success of the case.

Errata Sheet – Acceptable Corrections

A client may be tempted to suggest changes that are more favorable or to elaborate on a given answer to avoid ambiguity. However, the errata sheet process is not a ‘do over’ or a chance to change one’s testimony. Rather, the intention is to identify errors or misstatements that took place during the deposition. All changes are recorded, while both the original and corrected answer become part of the record. The corrections must therefore represent a genuine mistake of accuracy and ambiguity.

What Clients and Witnesses Should Know

You will want your client or witness to at least a basic level of familiarity with the read and review process. Indeed, making them aware of this process can significantly improve the ease of preparation and filing of the errata sheets:

  • The read and review process is time sensitive. The Federal Rules of Civil Procedure affords the deponent thirty (30) days, starting from the delivery date of the transcript, to submit changes. A failure to submit these changes within the given timeline means that the deposition will be accepted ‘as is’ – without corrections.
  • The deposition can only be corrected for inaccuracies. It must be clear to the client that the changes made do not erase the first record and both jury and judge will be privy to both answers. Your client should therefore understand that contradictory statements could generally have a negative effect on their case and he or she may face prosecution for perjury where no good reason is advanced for the contradiction.

The Responsibility of Paralegals and Legal Secretaries in the Read and Review Process

As the hired legal professional, whether you are a paralegal or legal secretary, you play a critical role in the preparation and filing of the errata sheets. And although it is important for the client to be part of the read and review process, it is the lawyer, paralegal and other support staff that will be combing through the deposition to identify the errors. While the process may be tedious, it is a necessary and important process.

Once the errors have been identified, it is your responsibility to record such errors on the errata sheet. If the error involves a change in the previously recorded answer, you must give a detailed explanation as to the change.

The handling of deposition errata sheets must be viewed as a critical process that has the potential to impact the outcome of any civil case. So although it’s in your client’s or witness’ best interest to ensure the accuracy of deposition statements, ultimately the responsibility for dotting all ‘I’s’ and crossing all ‘Ts’ — will fall upon you — the legal professional. This is all the more reason to pay attention to detail when dealing with errata sheets.

The Paralegal’s Guide to Scheduling Depositions

As a paralegal, your job is critical to the success of the law firm or organization that you serve. Indeed, paralegals are tasked with a vast array of legal duties, among them is participating in depositions. While the primary depositional duties are taking notes and observing the plaintiff’s behavior, paralegals may also be asked to schedule depositions. However, due to the amount of detail and the number of steps involved, doing so can be intimidating.

As a paralegal, your job is critical to the success of the law firm or organization that you serve. Indeed, paralegals are tasked with a vast array of legal duties, among them is participating in depositions. While the primary depositional duties are taking notes and observing the plaintiff’s behavior, paralegals may also be asked to schedule depositions. However, due to the amount of detail and the number of steps involved, doing so can be intimidating.

Having worked for many years in the court reporter profession, I wanted to provide a helpful overview for paralegals seeking to schedule their first deposition. If you follow the steps provided below, you should find it to be a manageable process, despite its complexity.

Scheduling a Deposition – How to Document the Scheduling Attorney

If you are looking to schedule a deposition but are not the scheduling attorney, you must be prepared to provide details on the scheduling attorney, including contact information. The typical contact information required is:

  • Name of the scheduling attorney
  • The name of the firm
  • Physical address of the firm
  • Best phone number
  • Fax number
  • Email address

It’s vitally important that you include this information in the deposition request because the court reporting firm needs to be able to reach the attorney in order to share any news or information that they might receive.

The Notice of Deposition and Case Detail Documentation

Upon contacting the court reporting firm to schedule the deposition, typically you’ll be asked for the case caption, which contains pertinent information, such as the name of the witness, docket number and case name. This information is also included in the notice of deposition, so you should keep it handy. If you do not have the notice of deposition prepared at the time of scheduling, it is critical to send it as soon as you have it ready.

There are several options for the method of delivery, however, email tends to be the most preferred, as it offers several unique advantages. First, the court reporters will immediately receive your notice of deposition, and typically they will confirm that they have received your emailed notice. Alternatively, you may choose to schedule your deposition online, through the court reporter’s website. In this case you simply enter the relevant information, and the court reporting firm will contact you to confirm that they have received your notice.

Scheduling the Proceedings

When scheduling the proceedings, you must provide the following information:

  • The name of the deponent
  • The chosen location for the proceedings
  • The time and date that the proceedings will begin
  • Whether there is a requirement to schedule a conference room

Estimated Duration of Proceedings

Most firms will request that you disclose the estimated length of time required for the proceedings. This will help the court reporting firm in scheduling any other depositions, as court reporting firms typically handle many depositions in any given day. If you believe that your deposition may take up the entire day, it is important to notify the court reporting firm, so that they can provide you with a reporter who is available for the number of hours required.

Other Items to Gather

A case description is highly useful to the court reporting firm. If the deposition is going to deal with medical or technical language or other professional jargon, your court reporting firm may choose to send a reporter with more experience in the language spoken by professionals in those fields.

You should consider whether you will need special services from the court reporting firm, such as a videographer, a real-time reporter, streaming video, conference room reservation, an expedited transcription, a speakerphone, online deposition, or an electronic transcript. If any of these services are pertinent to your deposition, make sure you let your court reporting firm know beforehand.

In closing, scheduling a deposition can be an intricate process, especially for new paralegals. Nonetheless, it’s a task that becomes more manageable with time. The key to developing proficiency in depositions is repetition and the sort of foreknowing, that only comes from ‘hands on’ experience.

Five Best Practices for Managing Video Depositions as a Paralegal

difficult video deposition witnessesAs a court reporter, I’ve seen firsthand the extent to which video testimony can improve depositions by cutting costs and improving trial effectiveness. Indeed, this has a lot to do with the rising popularity of the practice and it’s why you, as a paralegal should familiarize yourself with best practices for video depositions.

Video depositions are quickly becoming commonplace in litigation. While the attorney and the witness are the stars of the show, the paralegal has an important role to play in several aspects of the video deposition, before and during the procedure. Here are several ways the paralegal can help the attorney manage a successful video deposition.

Preparing for the Deposition

Preparing for a video deposition can be an involving process. There are so many moving parts to manage and as a paralegal much of it will fall on your shoulders. Here are some of the steps that you may want to take to ensure that the ordeal goes smoothly.

  • Getting Organized – You should have the file organized and know where to find everything, just  in case the attorney asks for it.  It’s also a good idea to familiarize yourself with the general order in which the questions will be asked. This can help you determine what ancillary materials may be necessary at the deposition, such as prior pertinent depositions by the witness.
  • Secure the important parties – Paralegals are also tasked with ensuring that important parties attend the deposition. This includes contacting and possibly subpoenaing witnesses, hiring a videography team, as well as the court reporter.
  • Choosing a Room – The room that you conduct the deposition in will need to be large enough for the stenographer and videography team, along with the attorneys and the witness. You will also want to make sure that the room has comfortable seating, surfaces, easily accessible electrical outlets and good lighting (the video team will thank you for this later).
  • Getting the Room Ready – After you’ve chosen a room you can begin making it comfortable. A big part of this is stocking the room with beverages prior to the start of the deposition. You should also work to create an unobtrusive background. Blank neutral colored walls are actually preferable. Also, make sure that any video that is taken is timestamped and dated. If you’d like, you could even ask the sound person to allow you to do a sound check prior to the start of the proceedings.
  • Prepare the witness – Staring into a camera can be a frightening experience; even to the most outgoing of extroverts.  This is why many paralegals often confirm that the witness is comfortable before starting the deposition preparation.  The next thing that you want to do is guide the witness in how to remain focused throughout the process. Also, don’t forget to remind the witnesses to be truthful and polite and avoid being adversarial or anxious.

When filming begins, don’t forget to keep those water bottles and cups away from the witness. A witness might play with a bottle cap or take a drink when questioning gets tough. This is exactly what you do not want to capture on video, so it’s best to try and avoid these situations altogether.

Other Video Deposition Tips

Take thorough notes; observe the witness and the opposing attorney for nonverbal clues. Paralegals should listen intently and think on their feet. A witness or an attorney could expose  relevant and material facts during a deposition that may have been missed elsewhere.

Remind the attorney that the camera is always rolling and everything is on the record unless the parties agree to go off record. The microphone may pick up any side conversations, even when you’re not directly in front of it.

In this day and age, it’s important that paralegals be prepared to coordinate video depositions. The good news is that if you can use the tips above to help anticipate the needs of the witness, while also giving careful consideration to what’s ahead of you, handling these sorts of depositions through completion should get easier over time.

Why Demand for Real Time Court Reporting is Skyrocketing

The US legal industry has undergone massive changes, as has the legal market in Phoenix, Arizona. But one thing that continues to remain constant is the shift from standard court reporting to real-time Phoenix court reporting. This is no accident. Here’s a look at why this trend is likely to continue into the foreseeable future.

In recent years realtime court reporting in Phoenix, AZ has grown at a phenomenal pace and many believe that the industry will continue to grow. There are many reasons for the uptick. Not the least of which have been convenience, along with greater competition in the legal sector especially with Phoenix Court Reporters.

Nonetheless, these factors alone are not enough to account for the rapid expansion that the field has undergone.  Indeed, there are multiple issues at play rather than a single driver. However, before we explore the conditions that are driving the movement, let’s first take a look at what the term real-time court reporting really means.

What Is Realtime Court Reporting? 

There are several different variations of court reporting and real-time court stenography is one of them. The characteristic that separates it from standard court reporting is that when the stenographer inputs the short hand, it is immediately transformed into English text, whereas traditional court transcription requires someone to do this manually.

Many legal professionals would define realtime stenography as electronically sending the shorthand from the stenograph keyboard to a laptop, which runs real-time transcription software. In turn, the software transmits the testimony to electronic receivers that can display the feed on phones, monitors, computers and etc.

For example, if you were conducting a deposition and your reporter was transmitting the transcript real-time, here is how the process might look:

  1. The witness gives their testimony.
  2. The reporter uses his stenograph, which is connected to his laptop.  Since the laptop is already configured to run the realtime stenography software, as the reporter types his statements they are automatically converted into English text.
  3. As the statements are typed, they are simultaneously streamed to the reporter’s feed.
  4. Anyone who can access the feed would is then able to view and interact with the testimony.

Why the Legal Industry Is Turning to the Real-Time Model 

video depositions law firmHere are three reasons that real-time stenotype continues to generate massive interest within the legal community:

Technology Meets Convenience – With the advancement of technology it is now possible to store thousands and thousands of transcripts on a single SD card. Equally impressive is the fact that this gives you the ability to search among mountains of data to find and retrieve individual cases almost immediately.

Furthermore, the technology that is used to display the transcript shares much in common with the system used in close captioning for TV. In fact, this is another reason that proponents of realtime reporting enjoy using it so often — it also makes depositions accessible to the hearing impaired.

Additionally, unlike closed captioning on your TV – the user can actually interact with realtime transcripts.For instance, you can take notes on them, add bookmarks and etc.

Realtime Phoenix, AZ Court Reporting Simplifies Proceedings – Allowing legal professionals to read, notate or highlight certain portions of the testimony can help streamline your proceedings. Essentially, it gives you the opportunity to continue on with your proceedings – uninterrupted. Likewise, this type of court reporting is also beneficial to the other experts involved in the proceedings because it gives them realtime access to witness testimonies.

Realtime Transcription Cuts Costs – Perhaps the biggest reason that so many in the legal industry have been transitioning to real-time court reporting is the cost-savings. There are two ways to save money with real-time transitioning:

  1. Transmitting the deposition transcript – remotely – eliminates the need for costly travel arrangements.
  2. It gives attorneys who are unable to be physically present, during the deposition, the opportunity to ask questions and communicate with the onsite lawyers – remotely. This means that many of the secondary depositions you’ve had to make prior to going ‘realtime’ can be a thing of the past!

These are but a few of the reasons that realtime court reporting has experienced tremendous growth over the past few years. While there are undoubtedly more, the reasons above are the most commonly accepted explanations for the recent developments impacting Phoenix’s court reporting industry.

About the Author

Phoenix Deposition Services has been committed to meeting the needs of our clients for over 30 years. That’s why each of our Phoenix, AZ court reporters have been thoroughly trained in the field of court reporting and it’s also been the driving force behind our many successes.

So the next time you need deposition assistance contact the realtime court reporting professionals at Phoenix Deposition Services. Call us at 888-474-9337.