Shook Partner Mihai Vrasmasu and Associate Katie Mastrucci have authored “10 Tips for Deposing a Non-English Speaker” for the American Bar Association Section of Litigation’s Practice Points. Tapping into their years of experience as attorneys in Miami, Vrasmasu and Mastrucci provide guidance for attorneys who take depositions from witnesses who may require an interpreter or other intermediary.
For example, they suggest that attorneys inquire about the deponent’s level of English proficiency. “Inquiring into the deponent’s English proficiency may be relevant to a number of issues in your case, such as, for instance, how well he or she understood the subject product’s warnings or whether he or she could read the English-only ‘wet floor’ sign,” they explain. “So do not hesitate to ask how much English the deponent understands orally, how well he or she can read or write it, whether he or she ever took English classes, and whether he or she speaks in English in his or her daily life.”