Everyone working in the litigation field knows the purpose and uses of an errata sheet to a deposition and the reasons that a deponent is offered the opportunity to “read and sign.” Rule 30(e) of the Federal Rules of Civil Procedure states that all deponents are allowed 30 days in which to review their transcript and “if there are any changes in form or substance, to sign a statement listing the changes and the reasons for making them.”
Jason Hicks of Womble Carlyle Sandridge & Rice wrote a very informative article concerning the legal uses of an errata sheet and the arguments for what can be included and later used at trial. His article can be found at: http://www.lexology.com/library/detail.aspx?g=a46a6e9b-1196-48c7-be5d-d81b80ce63ef.
As a court reporting firm, we use the errata sheets for an additional purpose. We use them as an educational tool for our staff reporters. If a deponent changes an “I don’t remember” answer to a “Now that I’ve reviewed my notes, I remember that I wasn’t at work on that Friday” answer, we rarely do anything with that information. If, however, they’ve changed, for example, an acronym of CARP to CART throughout the entire deposition, we’d get in touch with our reporter and inform him or her of that change. This could be simply a matter of not hearing the witness well enough. They might want to make some changes as far as how closely they’re seated to the deponent or pay closer attention to the ambient noises within the room. Another example might be if they change “Sally” to be “Sallie” throughout the file. This, again, would be brought to the attention of the reporter so they might be more careful to get spellings of names, even if they think Sally is always spelled S-a-l-l-y, as it clearly is not.
As a general rule, most reporters want their work to be perfect and appreciate the chance to be even more perfect in their final product. We listen very carefully if a reporter gets defensive about a change a deponent made or offers several reasons (excuses) for why they didn’t have the correct term or correct spelling. Reporters who don’t want to improve or provide exceptional quality in their work rarely last long at our firm. Those who constantly want to be better, be faster, be certified, be the best that they can be are the ones who have stayed with us over the years.
You’re getting the best of the best when you book with Stevens-Koenig. Our reporters thrive on perfection and appreciate the importance of what they do…not only for themselves, but for you, your case and your clients.