As if Q & A dictation wasn’t hard enough, with only an attorney and witness speaking, now comes multi-voice dictation which adds one or two additional speakers to worry about. At just about every deposition you will attend in the future, you will need to be able to identify at least one additional participant, so having a system in place to accurately identify speakers is vital. This is especially important when you have multiple attorneys arguing, sometimes at a quick pace and often interrupting each other. It is easy to get confused, lose your rhythm, and drop. We’ve all struggled with this. Thankfully, it is a skill that becomes easier with practice.
Some schools rely on tape for multi-voice dictation where the voices introduce themselves at the beginning. I’ve heard of lone instructors changing their voice to designate a change in speaker. Some schools have actual speakers giving live dictation in front of the classroom, which I think is ideal, as I prefer a visual frame of reference. My school back in the day used a rigged contraption with lights on it, and my teacher would switch a light on to identify which “person” was speaking.
The reason I prefer a visual aid is because that is the way my speaker identification system is set up. This system is based on physical placement. It only matters if the person speaking is on the left or the right. So if someone on the left is speaking, I will hit certain keys on the left. If someone on the right is speaking, I will hit certain keys on the right.
As an example, let’s say you have four speakers in front of your classroom situated like this:
Speaker (left) Questioner (Q) Witness (A) Speaker (right)
Your dictation will be in Q&A format until the speaker on the left interrupts. When that happens, I hit SKWRAO. When the speaker on the right interrupts, I hit EURBGS. This eliminates precious seconds trying to remember a name, if he’s the plaintiff’s lawyer or the defendant’s lawyer, if he is conducting direct or cross, or any other identifier. It allows you to react immediately based on a visual cue.
When you become a reporter, one day you will be faced with multiple people seated around a conference table. Consider the seating diagram below for nine additional participants besides the questioner and the witness. The same principle applies. There is no need to commit their names to memory. You only have to assign them a “token” to keep track of them. I have put the appropriate token next to each person based on their seating placement.
*For the questioner, I will write SKWRAO when he speaks in colloquy. He is assigned that first token. If the witness speaks in colloquy, I write WEUT/WEUT.
Counsel SKWRAOT Counsel SEURBGS
Counsel SKWRAOL Counsel TEURBGS
Counsel SKWRAOP Counsel PEURBGS
Counsel SKWRAOF Counsel HEURBGS
Questioner SKWRAO Counsel EURBGS
(Reporter sits here)
If there is a person sitting at the far end of the table, opposite me, I usually hit the whole keyboard, which is also my designation for a judge.
Notice the pattern. For the people on the left, your core bank will always be SKWRAO. You will only need to add the F, P, L, or T, assigning them in order as they appear down the table. The same applies to the people on the right. Your core bank will always be EURBGS. You will only need to add the H, P, T, or S, S being the person furthest away from you. I hit my tokens twice because I am less apt to mistake it for a word.
There will be times when there will be more people than you have tokens for. At that point you will have to become creative and assign other identifiers for people, such as what they’re wearing, or come up with other tokens using the upper banks, STPH and FPLT. The scenario noted above, however, will be more than adequate for the majority of the time. This system has worked very well for me over my career. Try it and see if it works for you.
If you are practicing multi-voice dictation by means other than visual cues, it is definitely harder, in my opinion; however, this system can still work. Just mentally assign each voice a token. I think a left or right token is an easier option than writing a name, for instance.
Identifying speakers in multi-voice dictation certainly adds another layer of difficulty, especially when you are pushing for speed. The key is to not overthink it too much and hit the token the second you hear a different voice. There will be times when you hit the wrong token. Be alert during the editing process to any comments or objections that seem out of place for that particular speaker. Let context aid you in choosing who the correct speaker should be. Obviously, the faster you can write, the more time you will have in your reservoir to be able to correctly stroke a Q, an A, and any colloquy that is interspersed throughout the dictation.
As much as you may be struggling with speaker identification now, there will come a time when you will be confident in your abilities to accurately identify everyone in a room. You will actually welcome seeing many lawyers at a deposition because each lawyer represents a potential sale. One reporter from this office got called out on a last-minute assignment and ended up selling 21 copies! (Thankfully, not everyone spoke.)
So, as always, keep practicing. “Luck is what happens when preparation meets opportunity.” – Seneca