Tilting the Economics of Depositions Back in Favor of Plaintiff & Trial Counsel.
Through our sister legal videography and trial support operations at Litigation Dynamics, we have watched plaintiff and boutique trial attorneys increasingly use video-recorded Depositions by Written Questions (DWQ) not just for records custodians, but for treating doctors, non-retained experts, and key fact witnesses. We built the Koce DWQ App so you can depose witnesses without spending your hours on it—and we are opening our Early Access Program for free in exchange for your feedback.
Why Oral Deposition Economics Penalize Plaintiff Attorneys
For decades, insurance defense firms have relied on the sheer expense and scheduling drag of TRCP 199 oral depositions to ration how many witnesses a plaintiff attorney can afford to put under oath. When a single oral deposition costs $2,500 to $5,000+ in reporter, videographer, and professional appearance fees, deposing three treating providers or fact witnesses on a $50,000 or $100,000 policy-limits case punishes your client’s net recovery.
Depose Witnesses Without Spending Your Hours on It
Put treating physicians, non-retained experts, independent eyewitnesses, investigating officers, and narrow corporate designees under oath early—without burning an entire afternoon in a Zoom room or absorbing a $3,500 invoice.
Witnesses Prefer Answering Written Questions on Their Schedule
Treating doctors and cooperative third-party witnesses dread canceling half a day of clinic or taking unpaid time off work to sit through oral cross-examination. With a video DWQ, witnesses review the propounded questions and record clear, sworn answers on their own schedule.
Lock In Testimony & Counter § 18.001 Challenges Early
Use targeted TRCP 200 written questions to let treating physicians and non-retained experts establish medical necessity and causation when defense files boilerplate CPRC § 18.001 counter-affidavits, and freeze eyewitness accounts before memories fade.
| Witness Type | The Old Way (TRCP 199 Oral Depo) | The Koce DWQ Way (TRCP 200 / FRCP 31 Video DWQ) |
|---|---|---|
| Treating Physician / Non-Retained Expert | $1,500–$3,500 minimum block fee, 72-hour cancellation penalties, half-day clinic disruption, and 4 hours of attorney time. | Answers 8–12 focused causation, medical necessity, and billing questions post-clinic with the patient chart in hand at a fraction of the cost. |
| Independent Eyewitness | Forced to take unpaid PTO, coordinate 3 attorney calendars, and face intimidating cross-examination for a $10 check. | Clicks a secure link on their lunch break, verifies photo ID, takes the oath on camera, and answers propounded questions clearly. |
| First Responder / Fact or Damage Witness | Subpoena scheduling headaches, shift conflicts, or leaving testimony uncollected until trial. | Authenticates crash reports, scene photos, and physical observations under oath in 15 minutes from their desk or phone. |
Built for Plaintiff Attorneys, Boutique Trial Firms & Litigators
Legacy record retrieval clearinghouses only understand how to send a fax to a hospital records custodian. They have zero workflow for substantive witnesses. We designed the DWQ App specifically for trial teams who want to move fast:
Personal Injury Trial Lawyers
Handling motor vehicle, commercial trucking, and premises liability dockets where locking in treating doctors, scene witnesses, and non-retained experts early drives settlement leverage without inflating case expenses.
Solo & Boutique Civil Litigators
Competing against 200-lawyer defense firms by using deterministic automation to conduct thorough multi-witness discovery without needing an army of junior associates to sit through routine depositions.
Existing Genius & Litigation Dynamics Clients
Attorneys already managing active matters on Genius who want completed DWQ video recordings and 25-line transcripts to import into their case file with a single click.
How the Koce DWQ App Works End-to-End
Tied directly to your matters in Genius (`dwq.koce.com`), the platform handles question staging, statutory notice tracking, witness identity verification, verbatim question reading, video recording, and multi-pass court-reporter transcription.
Select Your Matter & Stage Objection-Proof Questions
Click into any active matter in your docket, enter the witness and target date, upload your Notice of DWQ or Subpoena, and build your written question sequence using drag-and-drop ordering and built-in TRCP 200 / FRCP 31 predicate templates (including cross, redirect, and recross rounds).
Government Photo ID, Liveness & Recorded Solemn Oath
You send the witness a single secure link—no Zoom install required. Before Question 1, the studio presents formal statutory disclosures (FRCP 28, 30(b)(5), 31; TRCP 199, 200; penalty of perjury), captures a SHA-256 hashed snapshot of the witness’s government photo ID and face, and records the on-camera anti-coaching attestation and solemn oath.
Sequential Video Recording Without AI Ad-Libbing
Under FRCP 31(b) and TRCP 200.4, propounded written questions must be read verbatim. Our examination studio reads each written question aloud clearly using deterministic neural voice synthesis while displaying the question text and any attached exhibit—recording high-definition video and isolated 16 kHz audio with local crash buffering.
25-Line Court-Reporter Formatting & Case Import
Once the witness finishes, our 4-step workflow executes Pass 1 verbatim transcription with NCRA/AAERT pause notation (`(Pause.)` at ≥ 3.0s), runs a Pass 2 audio-grounded proofreader with an immutable diff audit log, formats a standard 25-line-per-page transcript (`[P:LL]`), emails you the link, and lets you import it into Genius in one click.
How the Early Access Program Works
We are keeping this simple: you get early access to the DWQ platform and can use it for free. All we ask in return is your candid feedback via email as you try it on real work.
Work Directly With Blake Boyd & Davis Jones
You will be working directly with Blake and Davis—the two people who run Koce and Litigation Dynamics. We will enable early access on your account for free, help you stage your questions if needed, and simply check in with you by email to hear what worked and what we should improve.
Put DWQ into one real witness task with us.
Whether you have an upcoming treating doctor, non-retained expert, or fact witness you want to depose by written questions right now—or just want early access enabled on your account to try it out—we would love to build this with you.
- ✓ Free Early Access: Use `dwq.koce.com` tied directly to your Genius matters at no cost during Early Access.
- ✓ Direct Support from Blake & Davis: Work directly with the two of us and our Litigation Dynamics legal videography and trial support team.
- ✓ Simple Email Feedback: No recurring meetings—just reply to our emails and tell us where the tool helps or gets in the way.
Early Access Request Received
Thank you. Blake and Davis will follow up personally by email to enable your workspace.