Notes taken while defending a deposition, for the benefit of mankind:
- Never give an exact date. Everything is "approximately."
- Use phrases like "in or around" instead of "-ish."
- "Yes" or "no" or any similar definitive answers are not acceptable. Usually.
- If you have something insightful or revealing to say, don't ever write it down.
- You are never wrong. If you do happen to be wrong, make a big deal about it to show everyone how magnanimous you are.
- Use big words like "magnanimous."
- If you can't remember something, say you can't remember "at this time," so that you can "remember" later on.
- Say "I don't recall" instead of "no."
- Use the phrase "refresh your recollection," even though it sounds creepy.
- If you are going to mischaracterize what someone has said, start off by saying, "I don't want to mischaracterize what you said, but..."
- Invite people to speculate by asking them not to speculate. For example, "I don't want you to speculate, but..."
5 comments:
I am teaching a class next week on depositions. I think I'll share some of your insights with my students. Won't they be impressed by the thoughts of a fancy New York lawyer?
HA HA HA If your class only knew...
A JEWISH fancy New York lawyer!
Ah, very important detail. I'll make sure to include the Jewish part. Hopefully, that will lend me some credibility.
Like you can be a fancy lawyer without being Jewish. Ha!
(Also? "On or about.")
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