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

[28eliminator]

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]

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

[Paul65K]

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

Welcome to a "Kinder, Gentler" forum

[havaduner]

Happy Thursday everybody!!!

[Wendi]

Morning all! Have a wonderful day. Unfortunately I can not partake in Thirsty Thursday as I do not drink alone.

[Eli]

Morning all! Have a wonderful day. Unfortunately I can not partake in Thirsty Thursday as I do not drink alone.

Wendi that's just a song...you can drink alone it's ok

[ChumpChange]

Morning all! Have a wonderful day. Unfortunately I can not partake in Thirsty Thursday as I do not drink alone.

Wendi that's just a song...you can drink alone it's ok

Maybe you two can get a conference call going?

[28eliminator]

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.

You just confirmed why one word answers would be the only intelligent choice...IMO

[Eli]

You just confirmed why one word answers would be the only intelligent choice...IMO

I can't tell you how often a "yes" or "no" answer is more damaging vs the narrative where the deponent explains the damaging portion away.

Did you...yes or no ...nailed the MOFO

Did you ...yea but...makes me cringe bc now I have to work them back into a "yes" or "no".

I've taken over 1000 depositions sometimes 2-3 months at a time 2 a day ...day after day. It's a skill...unless your being deposed that often and you know all the theories of the case and all the defendants defenses and have read every piece of evidence, spoken to the experts, sat in every deposition/read the transcript of every deponent before you, went to every hearing, read every motion, researched all the relevant case law your job as the deponent is to provide the answers to the questions you're asked...leave the rest up to the lawyers...they get paid pretty well let them earn their money.

I've had clients who don't answer the question and I want scream ...I had one if he was asked "state your name for the record" he replied "my legal name?" Well thanks for adding 4 questions to our already long day bc you know the attorney is going to ask you questions to figure out WTF you mean lol. He was a run away client and we were all ready kick him.