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