Phipps Tips Week 2

Remote Litigation: Exhibit Annotation Options

When you have a witness that is viewing an exhibit that you’re sharing, be aware that there are advantages and disadvantages to the methods available for having a remote deponent annotate (“mark up”) an exhibit during a remote deposition taking place via Zoom or Webex.

If you’re using the Share Screen function within Zoom, a witness can bring up the Annotate toolbar to create annotations as a video overlay being displayed over the screen share. It’s important to keep in mind that these annotations are not being made to the documents itself and, unless someone remembers to press the Save button, which creates a screenshot image file when pressed, the annotations will be lost forever as soon as the share is ended. For remote litigation, this is a huge vulnerability in terms of preserving evidence.

Instead of utilizing the screen annotation features within the videoconferencing software (e.g. Zoom, Webex, etc.), we would like to offer up another solution!

While an attorney is sharing the document via Share Screen, remote control can be passed to the witness which allows them to not only scroll through a document that they’re being asked about, but also allows them to utilize the annotation features built within the program that’s displaying the exhibit.

If your exhibits are in PDF format, Adobe Acrobat Reader is a free PDF viewer that is feature rich with annotation and commenting options, which can be utilized by the deponent remotely controlling your mouse. Instead of worrying about creating numerous screen images of each document section that is annotated, all annotations made remotely using Adobe Acrobat Reader’s Comment bar are maintained and saved within the actual PDF file.

You can download Adobe Acrobat Reader for free from

Learn more about the annotation features within Adobe Acrobat Reader…


You can reach out to me directly for additional information and training.

We look forward to helping you become a remote litigation expert!

Take care!



Scott Marcus
Director of Operations
Office: 414-409-1280
Direct: 414-409-1286