The Latest Craze – High Def PiP video depositions.

Over the past year, we have been getting more and more requests for Picture in Picture depositions. When covering overflow We’ve been asked to do it in various ways. What I’ve seen is there is not real “standard” for PiP.

Last month For the first time I presented at a trial that had nothing but Picture in Picture with document camera/ELMO depositions edited and played. We did not take any of the depositions, but here’s the good, the bad, and the really ugly..

Location and Layout:
Cameron County Courthouse

Located right on the border with Mexico in Brownsville sits this courthouse. I unfortunately, did not take a picture of the courtroom, but it was large and auditorium like. The judge sits high up in one corner and the jury on the opposite side of the room looking at him, maybe 75ft away. On the back wall between them is a very large (15′ or so) permanent screen that the witness sat in front of.

the courtroom layout

The projector was in need of a new bulb and some keystone adjustment but that’s what I had to work with. Unfortunately, the witness sits in front of the screen which wouldn’t allow me to use my own projector. We turned the row of lights along the wall off during playback, which helped, but it was still nowhere near “bright”.

The Good

Example 1

  • Example
  • Example

Example 2

  • Example
  • Example

These depositions were taken by the same company. The jury was able to follow along and had no issues reading the documents or seeing the witness. What makes them good?

  • The source files were in 1280×720.
  • The elmo was focused and oriented correctly (horizontal and vertical)
  • The document camera is in HD (or a high resolution)
  • The witness is put into the corner and the document camera is allowed to take up the majority of the screen
  • The witness is in 4:3 on the PIP.
  • I was provided a stream only file for each the elmo, deponent and mix.

I do have a few complaints (that did not cause any issues)

  • The deponent only stream is in 16:9. There were many points where you could see the attorneys “working” on their laptops
  • It looks like the 4:3 PIP was a crop done in post as the date:time is cut off. We prefer no time:date

The Bad

Example 1

  • Example
  • Example
  • Example

It should be obvious, but what makes this bad?

  • The elmo was oriented incorrectly for the first hour. Every document displayed was sideways.
  • When the camera was rotated, the operator did not horizontally orientate the camera. The document looked like it was being viewed at an angle.
  • From the start of the deposition the witness had an ipad blocking the view and red bull cans in the corner. 16:9 was too wide for this shot.
  • After the first hour we were able to read the documents

Example 2

  • Example
  • Example
  • Example

Some issues with this one as well..

  • The witness is in 16:9, but it’s been shrunk and does not fill the whole screen.
  • There is extra black space in the PIP. Both the witness and the camera are too small when in PIP
  • The jury was not able to read any document, was more of a distraction than anything.
  • The operator did not have the capability to plug a laptop in to display a video. The solution was to put an ipad under the camera and hit play. It did not look good at all.

The Ugly

Example 1

  • Example
  • Example

What in the world?

  • I’m not sure what the resolution on this is. Source claims 1280×720, but it’s clearly not HD and while it looks 4:3, it’s not.
  • Placing the PIP on top of the document feed is not a prefered location (side or corner please)
  • The document camera is not in HD.
  • This was the only source recorded. There was no deponent only feed.

Example 2

  • Example

You probably can not get any worse than this!

  • It came to me in a 320×420 MPG1.
  • You can’t see the witness nor the document.
  • I hope they didn’t pay extra for this.

My Takeaways

I think for PIP depositions to be accepted by the legal community there needs to be a more standard approach to layout and capturing specs. I’ve been against PIP for many many years due to the quality not being good enough to present in court. With today’s technology, it is much more cost effective and easier to produce than only a couple years ago.

Here is an example of the current way we’ve been producing our PIP (one is a powerpoint and one is a document camera):

  • Elmo Example
  • Example
  • We’ve disputed with overlaying the witness “on top” of the PIP feed in order to give more space to the document being displayed, but have found that sometimes the attorney highlights or points out information behind the witness feed.
  • We supply a camera, elmo/doc cam/computer and mixed feed files on every job. This allows the end user to do anything they want. I almost had an issue of playing a cut that had a document containing insurance information being shown, I would have had to take it into premier and edit it out by hand, wasting valuable time in a middle of trial, late night editing marathon.
  • We always shoot the witness in 4:3 and the document camera in 1280×720. The deliverable product is a 1280×720 mp4.

  • – Blake Boyd (

Comments 13

  1. I have had the same experience with the PinP depos that have come across my desk. I think the nationals have a cookie cutter production process and they treat it as if it was a standard deposition. It has to remain HD!
    I wonder also, were you able to display in HD? Or were you constrained to a 4:3 projector and resolution?

    1. Post

      I don’t believe it would qualify as HD from the projector. It clearly needed a bulb change about 2 years ago, unfortunately what you typically find in smaller courts.

      The “default” resolution by the manufacturer was 1280×1024, so I set my laptop to present at that resolution, but I’m not sure what the court’s video distribution switch did with the signal. Although, the videos and documents displayed without stretching .

  2. Thank you for putting this collection together. It allows for a lot of great discussion!

    The time and date being on the deponent video is an issue with how the video is requested by the scheduling party. That is not a P-in-P issue. That’s a communication issue.

    There are many variations on what a P-in-P switcher can actually do. Some of the less expensive P-in-P switchers do not allow cropping of the small image. Others require all inputs and outputs to be the same format (i.e., if you want 720p out, you have to have all inputs be 720p in). Others use an overlay of one image on the other; you cannot reduce the size of the larger image, only the smaller image. Others allow for the size management of both images. There are not enough providers out there to be overly picky as to whether a camera shot is 1280×720 or not; if the operator is good, the shot should be centered so you can provide it as a 4:3 image if you want it.

    I agree that three streams should be recorded: exhibit, camera, and program mix. Time and date stamps are a local issue I’m not going to address. I am trying to figure out myself if I’m going to start asking whether all exhibits are portrait or landscape, and if they’re all one way or another, I may cheat the ELMO shot a little to one side to allow the PinP to fit in the image. I actually prefer putting the monitor screen to the right side of the witness and positioning the witness on the upper right side of the program mix; that way, the witness appears to be looking at the exhibit as they’re talking about it.

    1. Post

      Great points. We also try to make the witness “look at the document”, I forgot to mention that.

      Do not want to get into a time:date discussion either! I thought about leaving that part out, but it was somewhat obvious.

      In the past we used a Roland VR5 (which I do not recommend for depositions) and know the frustrations of not being able to customize all the different size/location/overlay/etc settings. It was very frustrating. I’m thinking about creating a post about our equipment setup, but it will take a lot of time to put together as there is SO MUCH to cover.

  3. Blake, this is a great comparison of the good, bad, and ugly of Picture in Picture deposition video. Embedded in this comparison you have also made note of a number of important requirements for PiP depositions, such as: location of the PiP window, orientation of the cameras, connectivity of the equipment, quality of the recording, and isolated feeds for later editing. It can be incredibly frustrating being the vendor that has to wrangle all of this material and then present it, but it sounds like you were able to pull it off.

    I will add one thing, we at the American Guild of Court Videographers are the first organization that I know of that has produced any kind of course or “standard” for what Picture-in-Picture depositions should entail and I would encourage anyone reading your post to consider taking the course before capturing any PiP Deposition Video themselves as it covers virtually every one of the scenarios and pitfalls outlined in your post.

    1. Post

      Great to hear the AGCV is on top of PiP. I would have never thought I would say this but.. I think PiP can be beneficial even if there is a trial tech present at the trial. On certain documents and pictures it really helps to be able to visualize what they’re talking about.

      On this case it was nice to see the witnesses draw on a map to explain what they saw when the accident happened.

  4. Nice post. It highlights all the pros/cons of doing PIP. I, like you, was against PIP for the longest time mainly because of quality issues. Once I discovered that you can produce an MPEG-1 at high resolution that can be synched and used in Trial Director I was sold. I think it’s very useful. Some of these samples look like they used analog equipment and obviously made a low res file. I just think if that’s all you can provide, then you need to let the client know, otherwise they will be disappointed.
    I typically overlay the witness over the document because the doc can be full screen. I let the taking attorney know to try and center the applicable section of the document on the screen. I have my 4 corners preset to move the PIP witness around if necessary and worse case I can use the joystick and/or resize. Always record a witness only backup. I did encounter the ipad issue once and the attorney did exactly what happened here. Had I known ahead of time he wanted to use an ipad I could’ve been more prepared, but this was also right after we put together our HD-PIP kit. Now I have a lightning adapter handy in the kit.

    1. Post

      I originally played the first video in mp4 within trial director. I had some pauses and slow load times between clips, so after the first depo I re-encoded everything into mpg1. With a bit of tweaking I couldn’t tell the difference between the source and the mpg1, which proved to have no problems throughout the trial.

      All of the screen captures from the post are from the source files.

  5. Great post Blake.
    Beginning this year, I have made it a practice to spend about 5 mins with the attorneys going over best practices with the document camera. I want them to have a pleasant experience using the technology. I used to assume because they order the PIP equipment that they knew how to use it; WRONG! WRONG! WRONG! As part of my 5 mins of me talking and showing them the Elmo, I show them the zoom in zoom out and I explain to them the importance if filling up the entire screen with the document. I explain that if the document is very busy they should use a pen or finger to point to where they are directing the witness to look. I tell them they do not need to point directly on to the document but can point in from the sides giving a reference to the witness and jury what area of the document they are referring to. This makes for a very strong presentation. I also tell the attorney I will be in the back of the room and if they have not zoomed in enough “do not be surprised if I zoom into the document for you”. I keep the remote for the Elmo in my hand and I do not hesitate to zoom in tighter on a document when it is needed. Once the attorney sees that I have done so if there need to adjust the documents placement he will scoot it to the right place. The use of the technology and its effectiveness is on display during the depo and hopefully in mediation or trial. Bottom line for all of us is to keep the “WOW” factor going. The 5 mins spent with the attorney pays back many times over if we do it right.
    I want to mention what some of us call a “stale document.” It’s a touchy subject to me. I have seen way too many PIPs where the document is discussed for 30 seconds but is on the screen for 5 mins. During my pre depo 5 mins with the attorney I tell him “I’m going to be listening to your questioning of the witness, if I see that the document is no longer needed I will take it off the screen and go back to the witness. If you look up at the screen and the document is not there do not panic simply say: let’s go back to the document.” That is your que to me that you want to ask more questions from the document and I will switch back to the PIP. It is pretty satisfying to hear those exact words come out of the attorney’s mouth during the depo. It gives the feeling of working like a team to utilize the technology.
    And I should have said as part of our setup we provide the program mix for the attorneys to view the live mixing on a 27” monitor just in front of the Elmo and to the right of the witness. We only show the source feed to the witness on a 22” monitor so they do not have to see themselves during the deposition.
    It is pretty cool when you hear the out of town attorney that is sitting on the other side of the table say; I never seen a setup like this before and it is very effective what’s it called? Hopefully he’s asking because he wants to use it on his depositions.
    We all owe it to each other to try and educate our user/consumers on how to use the PIP technology in order for there to be a positive experience for everyone.
    As others on this post have mention the witness in the corner facing into the document looks good and we practice that with our setups. We have the ability to crop our small video window to minimize encroachment into the areas of the document that is being discussed. Presets for moving the small video into all corners is a must. In a worst case the videographer should not be afraid of removing the witness off the screen completely if the document’s discussion demands the full screen and the witness video is obstructing the view of the document. We use the witness over document because it gives us use of the full width of the screen for the document as opposed the screen sharing configuration.
    I was recently in a trial and all the video was done by one of Texas’ largest court reporting firms. I would have to say that as a provider of PIP video I was appalled and disappointed at the quality of the video delivery. There were 12 witnesses in the case and all done by the same Texas court reporting firm. They all had PIP services provided. The craziest thing was that the video was delivered to the customer as a 320×240 @ 1400kbps 16:9. I will give them credit that they did provide a witness only video, but it was delivered as 720×480 Mpeg2 @ 1400kbps 16:9 variable bit rate. I have no idea why and I can find no logic for them choosing the formats of their deliverables. Maybe someone can chime in and enlighten me. The 320×240 totally killed any possibility of being able to see the documents whatsoever. I was glad that there was a witness only video but I had to re-encode everything to mpeg1 constant bit rate so that there would not be any issues for playback. My clients choose to use the witness only video for our video offers.
    In my experience there are only 2 trial presentation software programs that can play back Mp4, Visionary and InData’s TrialDirector. I am a staunch user of Visionary and it works great with Mp4 video. I have used it in trial several times without issues. I have tested video that we shot and produce in both depoview disc and in TrialDirector without issues.
    Because of the fact that there currently is only 2 software programs that can playback the Mp4 video, we have chosen to use InData’s whitepaper specs as our Mp4 deliverable. Visionary can higher bitrates without issue. On our witness only is delivered like any other witness only. (Mpeg1 and 4:3)
    I don’t know how the Large Texas firm thinks they are doing the PIP market any justice when they reduce the video down to a 320×240. It’s my opinion that if an attorney sees that low ( crappy ) quality of video played back in the courtroom, he/she will not become a user/consumer of PIP as a service. Those of us that have invested into our PIP kits have lost on future sales because of this poor display of the PIP technology.

    Carlos Hinojosa
    OTS Legal Video
    144 San Jacinto
    Mission, Texas 78572
    956-624-6947 (C)
    956-580-3901 (O)
    866-256-4670 (F)

  6. Folks, the secret to smooth MPEG-4 playback is to match the GOP to the frame rate of the video. A 29.97 fps should have a 30 frame GOP, as an example. MPEG-4 is a streaming format and the GOP can be stretched to 400-600 frames. That’s great for streaming but lousy for what we do.

    I was playing with other settings, but the GOP/fps match made the video play like an MPEG-1 while still having the smaller size and softer compression characteristics of the MPEG-4. It becomes very suitable for courtroom playback.

  7. Pingback: Video Depositions: Picture in Picture - SA Legal Solutions

  8. This is what I’ve been looking for! Really bad examples of what lawyers could get stuck with! I want to ask permission from SA Legal Solutions to copy and paste the “bad and the ugly” to my new website. Let me know because this is the word we need to get out to clients that want to save a few bucks. Coastal Bend Video and United Video Productions have pushed for years for all the video company’s in South Texas to up their game but we end up getting cricket silence in return…we both know guys that have full HD depo kits and output composite to a DVD burner! That’s a glorified VHS! It’s ridiculous but its going on all over so I’m all about educating our consumer and gaining ground with visual clarity.

  9. Hello
    I’ve been a legal videographer in Mississippi for about 15 years now. I have never got a request to do this type of service until about a week ago. I had to sync the elmo/doc cam in post to make a PIP. I want to offer live switcher PIP service in the future and was looking in to getting a switcher. Does anyone have a recommendation of what brand and model would be best for deposition work? Also I am very happy to see a platform like this that helps promote good professional work within our field. Hopefully I’m not coming in too late. Thanks

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