Time is of the essence when planning international depositions, so organization is vital.  Using a flow chart or checklist as you prepare for international depositions will not only keep you organized and on track, but will also set the process in stark black and white, reducing any anxiety you may have.  Working with a court reporting firm with significant experience scheduling and covering international proceedings will further simplify the process!

Initial Steps/Preparation:

1. Verify local laws governing depositions before planning depositions in a foreign country.
2. Verify the code of civil procedure for your state (most authorize the taking of depositions in a foreign country).
3. Review travel requirements – visa, passport, vaccinations, etc.
4. Determine if the witness is a willing witness.
5. Discuss and resolve the administration of the oath with opposing counsel.

Scheduling Steps:

1. Determine the court reporting services needed:
   1. S.-certified court reporter?
   2. S.-certified videographer?
   3. Interpreter?
2. Identify your preferred location:
   1. Number of attendees?
   2. Conference room in a hotel?
   3. Conference room in a law office?
   4. S. Embassy or Consulate? (E.g., Japan or Germany permit depositions only on Embassy/Consulate grounds)
3. Determine if videoconferencing is required (if it is not, skip to step 4):
   1. Location in host country?
   2. Location in U.S.?
   3. Location of reporter, videographer and interpreter?
      1. Is travel needed for the court reporting team?
   4. Schedule deposition dates:
      1. Start time
      2. End time

Steps for Travel:

1. Visa requirements met?
2. Passport requirements met?
3. Flight reserved?
4. Hotel accommodations arranged?
5. Car service arranged?

Logistics for your court reporting services:

1. Protective Order sent to the court reporting firm, if applicable?
2. Transcript Options?
   1. Transcript turnaround time
   2. Where to send rough ASCII and final transcript
   3. Number of realtime hookups and/or laptops or iPads needed
3. Notice of deposition sent (to all counsel and the witness as well)?
4. Prep materials sent?
   1. Complaint and/or Answer to Complaint
   2. Subpoena
   3. Previous transcript(s)
   4. Court order (if applicable)
   5. Patent(s) (if applicable)

There are countries which entail additional steps (Japan’s Special Deposition Visa, for example), but the above is a good starting point as you schedule depositions overseas.  Keep in mind, your court reporting firm can reserve a conference room at a hotel or facility if needed, and can assist you in determining any visa requirements for your destination.  Additionally, an international court reporting firm will have reporters, videographers, and interpreters living throughout the world, who can provide informed hotel and restaurant recommendations and also give you tips on local traffic, shopping, and etiquette.  Not to mention no or minimal associated travel costs!