Deposition Tips for Attorneys

Today I am going to write about tips for attorneys when taking depositions.  I have been a court reporter for 29 years, starting out as a typist for reporters.  Yes, back when erasers were used and carbon sets and actual typewriters.

IBM SELECTRIC

1.  Take business cards with you.  Court reporters need your business card and information, along with an email address.

2.  Introduce yourself to the court reporter.   We may be the silent person in the room, but we do like to know that you know we're there.  Ask if the reporter has the style of the case or a notice.  Offer up unusual spellings or proper names. 

3.  Prepare your deposition questions ahead of time.  I know it's got to be hard to know which questions you need to ask, and it's not unusual to forget a few questions.  It's okay to come in with a list of your questions.  Personally, if I see an attorney with 15 pages of questions, I know we are going to be there for a while and that's okay.  That attorney is prepared and it pays to be methodical.

4.  Ask your questions slowly, directly and loud enough for everyone to hear you, especially the court reporter and the witness.  An attorney who spits out questions just encourages the witness to speak fast and butt in.  Keep it smooth.

5.  If you MUST read from a document, please read slowly.  Imagine being in a race where you are moving along at a comfortable pace, keeping up with everyone around you, then all of a sudden those around you are speeding up and leaving you behind.  It's hard to get to the finish line when you're left at the gate. 

Plus, the witness can't keep up with you if you're reading from a document at a fast rate.  

Most likely, the witness will say:  What, I don't understand, say that again, or I don't know what you mean.  Then opposing counsel wakes up and objects.  Time wasted.

6.  I, for one, love it when an attorney marks their own exhibits.  Some attorney says, Mark this as Exhibit so-and-so, and hands it to the reporter.  The reporter stops to mark it, and said attorney just keeps right on asking another question.  Hello?  I have only two hands.   Marking your own exhibits gives you and the witness a second of downtime to think about the exhibit about to be shown.

A-n-t-i-c-i-p-a-t-i-o-n.  I bet you will notice that the court reporter will smile and appreciate the lull.

7.  If you're going to be at the deposition for a while, take a break at least every hour to hour and a half.   That will give you time to think about other questions you may want to ask.  You can always ask the reporter to read back something to you during a break if you need clarification.  And, the reporter is probably in need of a stretch break, too.

That's all of my tips for today.  Transcripts await editing!

Ten Day Challenge - Day 10 - Ten Secrets

Ten Secrets

I will have to pass on this one.  It's bad enough that my friends know my secrets.  I'm surprised they haven't sold me out to National Enquirer.  

I also learned in the 9th grade that putting pen to paper, or fingers to keyboard, that what is written sometimes comes back to bite you in the ass. 

Ten day Challenge

I am way behind on the 10 day You Challenge so going to double up on a few.

 One Picture

Seriously?

 

Two Songs

I have so many favorite songs, it's hard to narrow it down.  I like all types of music.  Grew up in the late '60s and '70s, so my tastes vary.  But my current favorites are:

1.  I Need You Now by Lady Antebellum

 http://www.youtube.com/watch?v=eM213aMKTHg

2.  Trip Around the Sun by Jimmy Buffett.  http://www.youtube.com/watch?v=BaKqwvGa6Bw

Actually love anything by JB.  

I used to sing A Pirate Looks At 40 as a lullaby to Queen when she was a baby.   http://www.youtube.com/watch?v=KNmULx6sMo4

Three Films

1.  Beaches.   http://en.wikipedia.org/wiki/Beaches_(film)

2.  One True Thing http://en.wikipedia.org/wiki/One_True_Thing

3.  The Big Chill  http://en.wikipedia.org/wiki/The_Big_Chill_(film)

Four Books

1.  Anything by Ann Rule.  2.  Five People You Meet in Heaven.  3.  Catcher In the Rye  4.  Gone With The Wind  

 

Five Foods

1.  Chinese  2.  Meatloaf   3.  Chocolate covered strawberries  4.  Cheese biscuits from Red Lobster  
5.  Cake with butter cream frosting. 

Six Places

where I've been & where I'd like to go

1.  Beach - any beach, preferably Folly Beach.  2.  Go to Ireland.  3.   Home sweet home.  4.  Mountains in the fall.  5.  Las Vegas.  6.  Hawaii

Seven Wants

not necessarily in order

1.  Convertible.  2.  Win the lottery or jackpot.  3.  10 years back for a do-over.  4.  World Peace.  

4. Grandchildren.  6.  Newer, smaller, more modern home.  7.  Retirement.

Eight Fears 

1.  Growing old.  2.  Poverty level in old age.  2.  Being sued.  3.  Tragic car wreck.  4.   Lingering, debilitating illness.  5.  Tornadoes.  6.  Children dying.  7.  Lightening storms.  8.  Hell

Catching up

I haven't posted in a while.  Tried to do that 10 Day challenge, but only made it for one day.  <sigh>  But have caught up with that this morning.  May be even a day ahead.

So what is new at the Honey house?  Queen2b has been attending her outpatient rehab meetings.  She comes home renewed and seems to be really enjoying them.  So far she has not done any Opioids and it has been about 3 weeks since she last used.  I am proud of her.  Her temperment, however, is still less than desired.  We did talk her into quitting her job as a waitress in a restaurant that serves liquor.  Nobody thought at this point it was a good environment for  her.  So she quit that, but has yet to find another job.  What does that mean?  That means she is always bumming money from me or Mr. Honey.  We refuse to give her cash, but have filled up her gas tank a few times.

Q2b and I have a real butting of the heads sometimes.  She calls me a "trigger" for wanting to use.  She comes to me and asks me things and I am brutally honest.  That is something she doesn't want to hear right now, is hard core, blunt honesty.  

The Boy is having a rough time, too.  He seems to hate Q2B.  Disgusted with her, and is at an age, 15, that he is embarrassed and does not want to have to deal with it.  He refuses to let her take him anywhere or pick him up, won't talk to her, ignores her when they are both in the house.  I'm setting both of them up with a psychologist on Monday.  Momma Honey cannot fix everything and their emotions are out of my control.

My plate is pretty full because it seems everybody wants to dump their leftovers onto my plate.  I clean the plate off and turn around and it's full again.  This is not how I expected my life to be at this point in my life.

So, on February 7th, I had a birthday.  Woot Woot.  I turned 56 years old.  Yes, I know, to some of you that sounds SOOOOOOOO old.  It is old.  When I was in my 20s and 30s, I couldn't even imagine being this old.  I'm young in mind and spirit but not in numbers.  And my body is also starting to feel the age too.  Poor me.  Youngsters, hear me out:  Exercise and keep your body toned.  You'll be glad you did when you get as old as me.  

Nine Loves

I follow some pretty neat women lawyers on Twitter.  They tweeted about this 10 day YOU Challenge, so I thought I would play along.  It is a little more uplifting than my previous posts.  Speaking of previous posts, I will update this weekend about my daughter, Q2B, and her progress.  It is positive.
Taking the cue from JudgyAmie, there seems to be no particular order this challenge should go, so I just picked one. 

Nine Loves

1.  First love was in 6th grade and his name was George.  Got my first kiss ON THE MOUTH!  Sadly George has passed away and I'm not sure how he died.  We went steady and I wore his ID bracelet.  Then after a while my girlfriend and I traded boyfriends and she got George for a while and I got Stanley.  Was easy enough to exchange ID bracelets.


2.  Second love was Ricky.  Met him when I was 15 and fell in love.  He was an older man, at the ripe old age of 17.  My parents wouldn't let me go out with him alone, so they would take us everywhere, movies, dances.  He was great to go along and it was worth his wait when I turned 17.  If you know what I mean, and I think you do.  Ricky and I lasted about 3 years.  He cheated on me and I cried and cried.  


3.  Third love was Gus.  He was a bad boy.  Married at 19, with a baby and in the middle of a divorce.  His "wife" lived with his parents.  I didn't care and believed whatever he told me.  Looking back, I can't believe I dated him while he was married.  So dumb we can all be when we are 19.


4.  Next love of my life was Greg.  Another older man.  I was about 21 and he was 4 years older.  He too was divorced, but with no kids.  I think I was his divorce rebound girlfriend because he tried to shape me by telling me what to wear, how to act.  We had a god-awful fight and that ended that.  


5.  Then there was Conrad.  I was 24.  Conrad was much older.  17 years older.  (Are we seeing a trend here?)  He was a criminal attorney and an alcoholic and divorced.  I loved him.  We had a great sex life.  Little did I realize at the time that I was feeding his ego by being the young woman on his arm.  We had an off and on relationship for about 4 years.  We always found a way back to each other until I moved to another city.  He died at the ripe old age of 65 from lung cancer.  A very heavy smoker who smoked Merits.  I didn't go to his funeral.  


6.  At age 29 I met Mr. Honey and we were married within six months.  No, I wasn't pregnant.  I had just vowed to myself that the next man I lived with would be my husband.  So we got married.  
We had two weddings, a secret one in our apartment by a justice of the peace, and then a semi-large wedding 5 months later in a church.  My mom wanted me to have a church wedding and they had no idea we were already married.  A-W-K-W-A-R-D.  We kept that secret for a long time.  


7.  I don't guess Loves means just men or significant others.  
Number 7 would be my daughter Queen.  She was perfect.  I loved her from the day I knew I was pregnant.  


8.  My second daughter Q2B.  She was always a challenge.  Feisty, outgoing, cute, made friends everywhere she went.  Still that way to this day.


9.  My son, The Boy.  What a surprise he was when he arrived the year I turned 40!  I had asked for a Miata for my 40th birthday and got a baby and a mini van.  God knew what he was doing.  The Boy's name had been picked out some 9 years earlier.