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Using an iPad to Recreate a Scene in a Deposition

May 25, 2011

When taking a deposition of an adverse witness, I sometimes want to pin down a witness on exactly where he was standing or where some other events took place. This can be difficult with simple questions and answers because even if the witness gives one explanation for where things took place, mere words may give the witness some wiggle room to later say that it happened differently. A good solution is to be armed with a picture of the area so that the witness can identify exactly where, in the picture, events took place.