What to Send Before Your Deposition

Start With the Notice

The deposition notice and any accompanying subpoena tell the reporter almost everything about the proceeding. Sending them early confirms the caption, date, location, and scope so nothing is assumed.

If the notice has been amended or the date has moved, send the current version and flag the change clearly to avoid confusion on the day.

• The operative deposition notice
• Any subpoena or document requests
• Amendments or rescheduling notices

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Appearances and Participants

Provide a list of who will attend and in what capacity. This helps the reporter record appearances accurately and prepare for the number of participants.

Include counsel for each party with firm names, the witness, and anyone attending remotely. Note any interpreter, and identify who is noticing the deposition.

• Counsel and firms for each party
• Witness name and role
• Remote attendees and observers
• Interpreter or accommodation needs

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Exhibits and Terminology

If you plan to introduce exhibits, share them ahead of time or explain how they will be handled during the session. Tell the reporter your marking convention so exhibits are numbered consistently.

Just as important, send a list of proper names, technical terms, and unusual spellings. Accurate spellings of parties, companies, products, and specialized vocabulary improve the transcript and reduce later corrections.

1. Exhibit files or a handling plan
2. Preferred marking convention
3. Names and titles with correct spellings
4. Technical or industry terminology

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Requirements and Contacts

Note anything unusual about the proceeding so the reporter can prepare. This includes realtime feeds, video, expedited delivery, or accessibility needs.

Finally, provide a day-of contact who can answer questions or resolve access issues quickly.

• Requested services such as realtime or video
• Turnaround and delivery preferences
• A reachable day-of contact and phone number