A recent article on these pages outlining helpful tips for remote depositions identified a problem concerning the use of exhibits during such depositions. The article suggested that “exhibits must … be organized and distributed in advance by the attorney conducting the remote deposition” because “waiting until the last moment to present exhibits is not advisable and will  cause delay and confusion.”

In fact, with appropriate software tools that problem is surmountable and a tactical advantage may be preserved. With such tools, exhibits can be held back and revealed to the witness and opposing counsel only when they are ready to be used. And this can be done efficiently, effectively and without delay.

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