Good Morning Everyone.......It's Thirsty Thursday

**Tishimself** · 10-17-2013, 06:28 AM

Good morning all......yawn....I am off today..having a cup of coffee, and relaxing.

**314joey** · 10-17-2013, 06:31 AM

Originally Posted by Paul65K

Over the years I got used to Depos.........I came to understand that most (not all) attorneys are "Jackwagons" and I usually have more knowledge of the given subject matter then they do......on the other hand I love to give one word answers....it really pissed them off

Those days are over for me.....damn I miss the "Good old days"

My Daughter is a attorney so I have to love her, lol...........I used to deal wit lots of attorney for work, they're no different than anyone else, there's great one's, good one's and chitty one's.

And, yea, I miss the good ol' days too.

**Eli** · 10-17-2013, 07:02 AM

Good morning everyone!

I love taking depositions! They are super fun! Specially when you have a deponent that likes to give 1 word answers. In fact, I was taking a SDPD officer's depo once and he was brilliant at 1 word replies. He was being very difficult and 30 minutes into a his deposition we were barely at his employment information. I really didn't want to spend 11 more hours with him.

So, I asked the court reporter to go off the record...I informed the deponent that I'm fully aware of his tactics...I told him my billable hour rate...I reminded him I get paid by the hour...I asked him how much he was getting paid to sit there and give his deposition, (unrelated to his job so $0) then I said, "I'm pretty quick I can get this done in 2 hours ...I will get my answers the easy way or the slow way...how long do you want to sit here?" He laughed and said "okay you got me". The rest of the deposition was a breeze and super fun!

He was suing my client so...I had to depose him

**Paul65K** · 10-17-2013, 07:06 AM

Originally Posted by Eli

Good morning everyone!

I love taking depositions! They are super fun! Specially when you have a deponent that likes to give 1 word answers. In fact, I was taking a SDPD officer's depo once and he was brilliant at 1 word replies. He was being very difficult and 30 minutes into a his deposition we were barely at his employment information. I really didn't want to spend 11 more hours with him.

So, I asked the court reporter to go off the record...I informed the deponent that I'm fully aware of his tactics...I told him my billable hour rate...I reminded him I get paid by the hour...I asked him how much he was getting paid to sit there and give his deposition, (unrelated to his job so $0) then I said, "I'm pretty quick I can get this done in 2 hours ...I will get my answers the easy way or the slow way...how long do you want to sit here?" He laughed and said "okay you got me". The rest of the deposition was a breeze and super fun!

He was suing my client so...I had to depose him

Hence my comment about most (not all) Attorneys

**28eliminator** · 10-17-2013, 07:11 AM

Originally Posted by Eli

Good morning everyone!

I love taking depositions! They are super fun! Specially when you have a deponent that likes to give 1 word answers. In fact, I was taking a SDPD officer's depo once and he was brilliant at 1 word replies. He was being very difficult and 30 minutes into a his deposition we were barely at his employment information. I really didn't want to spend 11 more hours with him.

So, I asked the court reporter to go off the record...I informed the deponent that I'm fully aware of his tactics...I told him my billable hour rate...I reminded him I get paid by the hour...I asked him how much he was getting paid to sit there and give his deposition, (unrelated to his job so $0) then I said, "I'm pretty quick I can get this done in 2 hours ...I will get my answers the easy way or the slow way...how long do you want to sit here?" He laughed and said "okay you got me". The rest of the deposition was a breeze and super fun!

He was suing my client so...I had to depose him

So you tell your clients that are being deposed to be forthcoming with all information... no one word answers? yeah right

**Eli** · 10-17-2013, 07:21 AM

Originally Posted by 28eliminator

So you tell your clients that are being deposed to be forthcoming with all information... no one word answers? yeah right

I tell them to answer the question that's being asked. As shocking as it may seem...sometimes we just want the deponent to say "yes" or "no". We don't want a narrative.

Typically, by the time an attorney is taking a deposition they have already done most of the discovery. There is very little new information. I usually just want to get the deponent to say damaging things on the record...I already know the answers bc they responded to written discovery.

For example, I took the depo of the most pompous geologist once. Guy thought he was god...I deposed him for 2 days and got him to admit all the repairs and findings were his "expert" opinion and not any of the other experts...he was elated that some chick finally acknowledged his work...then I disqualified all his findings bc he wasn't a civil engineer...I'm such a Bunch****...I still remember the look on his face when he realized what happened. I knew going in exactly what I was doing...nothing he said surprised me.

If you were my client and I just got you out of paying a minimum of $7million you'd love me too!

Edit: I didn't put the **** behind the word Bunch apparently the C-word is forbidden