Using the iPad for Witness Preparation

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Have you purchased an iPad2 and are now looking for a good use for your original iPad? Consider using it as a deposition preparation tool. I am a trial attorney and primarily litigate complex business cases. My practice is national in scope, and I am often on the road preparing witnesses for deposition, hearing, or trial testimony. This typically involves reviewing dozens if not hundreds of documents with the various witnesses. Prior to the iPad that often meant lugging around two or more bankers boxes all over the country. NO MORE.

Now, I load the documents for review on both my iPad2 and my original iPad (which is been sanitized to remove any sensitive legal documents or information in cases other than the one involving the witness).

Goodreader is my document review reader of choice. I like it because it can handle large documents and a large volume of documents. Goodreader also allows for the annotation or highlighting of PDF and documents. If your documents were produced in TIF format, they are easily converted to PDF.

The best way to load a large volume of documents into Goodreader is to use iTunes. To do this, connect your iPad to your computer. After iTunes opens, select your device. Then go to the menu at the top of the screen and select “Apps.” When the App screen loads up, go to the bottom and select Goodreader. In the box to the right, touch “add” and the use the browse feature to select the files you want to copy to the iPad from you computer.

Alternatively, if the volume of documents is not too significant, Dropbox can be used to transfer the documents. If you’re going to use this method, then I recommend creating a folder with the case or witness name on your PC, loading copies of all the review documents into that folder and then moving the entire folder folder into Dropbox. On the iPad, the folder will appear in Dropbox. Simply select the folder, and individual documents will appear. Open each of the documents individually Goodreader to move it over. This requirement to individually open each document in Dropbox and them move it to Goodreader is why I prefer the iTunes bulk transfer method.

Whichever method you use to load the documents, the end result will be a bunch of individual files in Goodreader. My practice is to create a folder for the witness or the case using Goodreader’s manage files function, and then move the documents into that folder. If you have a number of witnesses to prepare, simply make a folder for each witness.

For the actual prep session, provide the witness with their own iPad loaded with the documents. These documents might be identified by descriptive title, by Bates number or by a simple exhibit numbering or lettering system.

Ideally, during the prep session the lawyer’s iPad2 will be connected to a projection device or monitor allowing the attorney to annotate or highlight documents and discuss them with the witness. The iPad 2 has the mirror function that permits display of the documents and anything else on the device. Goodreader also displays the documents on iPad1 if you turn on the video display feature (screen icon at bottom on file management screen). Because both the lawyer and the deponent’s iPads are connected by e-mail and dropbox (assuming active internet connection), the lawyer has the option of adding additional review documents to the client’s iPad on the fly during the course of the deposition prep.

At the end of the deposition, retrieve the witnesses’ iPad— thus, avoiding the problem of loose documents floating around. It should be noted that Goodreader has the capability to password protect folders and it is my practice to use this function.

So that’s deposition preparation using the iPad. We welcome any suggestions you might have that could improve upon our suggested methodology. Please post any comments to our blog site hytechlawyer.com or you can e-mail me at Bill@hytechlawyer.com

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