Has anyone taken one of these depositions? I have an older man with cancer who is a key witness in a Burglary of a Habitation case, and I am afraid he won't make it until the trial. I am looking for some examples of the motion you filed and some advice for the logistics of the deposition. Anyone do this by video that was introduced in trial?

I don't have a motion. But, do remember that for your depo to be admissible, the defendant either has to be present at the depo or formally waive his appearance at the depo. Also get a written agreement with defense counsel about handling objections during the depo rather than doing it the "civil" way. We had a defendant change lawyers after the depo, and he was able to keep out some of the depo that the first lawyer found unobjectionable at the time.

Heather: Check your e-mail. I have done a dpo and I sent you the material.