Doris O. Wong Associates has been hyperlinking documents since COVID-19 hit. Over the past few months, we have streamlined the process that we think works best for our clients.
SCENARIO 1: Email or snail mail the documents to everyone
PRO: Everyone has all of the documents for review
CONS: (1)Everyone has all of the documents whether they will be used or not. This could reveal your strategy. We had a scenario where opposing counsel objected to the documents before the deposition even started. (2)Cost to print and ship documents to all parties.
SCENARIO 2: Have Doris O. Wong Associates Hyperlink your documents
PRO: Only you and the court reporter will have access to the hyperlink list. Documents are stored on our secure server.
CON: In order to guarantee that you get the hyperlink list on time, we strongly request that we get the documents two days prior to the deposition/hearing to avoid conversion fees.
NAMING CONVENTIONS:
We request that when you send us your documents to be hyperlinked that you label them A-Z and not 1-100. When presenting a document via Chat, if you present A-Notice of Deposition, it can be marked it as Exhibit 1. This avoids confusion as to what is marked.
Oftentimes, counsel provides numerous documents that aren’t used and/or they skip around based on how the deposition is proceeding. By keeping the A-Z convention, there is less confusion on everyone’s part, e.g., A=1, F=2, D=3, etc.
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