One Camera, Nine People, Forty-Five Minutes: Placement Decisions in an Unscouted Room
The notice states the deposition will be recorded by audio-video means in addition to stenography. The only space available is a 14 x 18 ft conference room: one wall of windows behind the head of the table, a supply-air diffuser directly over the witness chair, and dark walnut paneling on the opposite wall. Nine people will attend - the witness, two defense counsel, two plaintiff counsel, a paralegal, the court reporter, an interpreter, and you. There is no opportunity to scout; you arrive 45 minutes early with a single camera on a tripod, one LED panel with a softbox, a lavalier, a boundary mic, and no crew. By phone the noticing attorney says she wants "a full frame of the witness and close-ups of every exhibit."
1. With 45 minutes and one camera, state the order in which you make placement and framing decisions, and explain what you are trading off at each step.
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Work from the things you cannot change outward.
- Eliminate the unusable shot first. A camera facing the window wall silhouettes the witness and blows out the background; a camera under the diffuser puts a bright ceiling edge in frame and parks your mic below the noise source. So the camera goes on the window side of the room, shooting toward the walnut wall, and the witness is seated with paneling behind him rather than glass.
- Set the axis. Put the lens roughly 15–30 degrees off the witness–examiner line, at the witness's seated eye height. When he answers, he looks near the lens and his face reads; the examiner's back does not fill the frame.
- Set the frame. Head-and-shoulders, a hand's width of headroom, and enough of the table edge to show exhibits. Verify on the monitor, never on the viewfinder alone.
- Assign seats before going on record, since the witness's chair is the one variable you control.
The trade-off is deliberate: you give up the flattering daylight and gain exposure control and a quiet mic position.
2. The noticing attorney's request for exhibit close-ups conflicts with the continuous, unedited recording requirement. How do you resolve it?
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The requirement is that the record be continuous and complete, not that the camera never changes framing - but any camera move that leaves the witness creates a gap in his reaction and can be read later as selective emphasis by one side.
Resolve it procedurally, not sneakily:
- Raise it before the first question and ask that it be addressed on the record, so all counsel hear the same rule.
- Get agreement that after an exhibit is marked, it is held to the camera for a few seconds, or displayed at a designated spot at the end of the table. Legibility at playback is the actual standard - an unreadable shot of paper satisfies no one.
- If no agreement is reached, stay wide enough that the witness, the document, and the person handling it are all in frame, and note in your log any framing change and its time.
- Never stop recording, never dissolve, and never instruct the witness yourself; seating and document handling are counsel's to arrange.
3. What recording settings do you lock in before the first question, and why does each one matter in a proceeding that cannot be re-shot?
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Everything is manual, because there is no second take.
- Dual recording: record to both card slots simultaneously, at the highest sustained bitrate the camera supports. One corrupt card must not cost the parties their record.
- Manual exposure, focus, and white balance: auto functions will hunt as people move, and a focus hunt on a key admission is permanent. White balance on a gray card under the final lighting setup, after the blinds and panel are set.
- Shutter and stabilization: fixed shutter; stabilization off on a locked tripod, on so it does not fight the tripod.
- Time and timecode: correct date/time and free-run timecode, so the log, the transcript, and the video can be reconciled months later.
- Verification: a 30-second test recording played back on the camera with headphones, plus a power plan that covers a session longer than scheduled.
Each of these is a one-time failure that no post-production can repair.