(Mr. Jones was conducting the deposition by phone.)
MR. JONES: And for the record, I can hear writing going on, and I just want to advise counsel not to be writing notes or advising the witness during the course of the deposition.
MR. DOE: And I’m not doing that. I’m making my own notes. I apologize. I didn’t know that you can hear it. I think the spider phone is awfully close to my paper. I don’t think John could read my writing anyway, David.
MR. JONES: Maybe you should have been a doctor, then.
Keep them guessing
Q. All right. So then any difference or drop down in wages from —
Q. Let me finish.
A. I’m sorry.
Q. Remember, I’m Captain Obvious on these questions, but you may not know what I’m going to ask you.
Carrie Arnold, RPR, CRR
Q. I think I’ve already asked you. You do not plan on offering any opinions about the growth rate of the cancer; is that right?
A. I will not.
MR. SMITH: You’ve asked her that three times, Carl.
MR. JONES: It’s very important that I close that door.
MR. SMITH: You slammed it.
Virginia Dodge, RDR, CRR
One and done
Q. Where did you get married?
A. In Haiti.
Q. Are you a U.S. citizen?
Q. When did you become a citizen?
A. I don’t remember the year. I don’t remember the year.
Q. Is it before you got married?
A. No. After the marriage, the wedding.
Q. Have you ever been married before?
A. No. And I am not doing it again.
Q. That’s the best answer I’ve ever heard.
Shoshana Kramer, RPR
Q. Have you retained any of those emails?
A. They may be on my computer.
Q. I’d ask you to make sure not to remove them, you know, from today forward, obviously.
MR. LAWYER: If they’re there.
MR. ATTORNEY: Yeah, if they’re there. If they’re not there, you’re free to remove them.
Liebe Stevenson, RMR
A delicate condition
Q. Other than the hypertension medication that you take, are there any other medications that you take on a regular basis?
A. No. I mean, if you class birth control pills.
Q. I don’t think that’s a medical condition.
A. No. Keep me from killing myself.
Kelly G. Palazzi, RPR
South Hackensack, N.J.
Coach them right
MR. JACKSON: Can you complete him in a short period of time, or do you need —
MR. BURR: If I lie to you, you’re not going to like me, so I don’t want to lie to you.
MR. JACKSON: Well, I already don’t like you.
MR. BURR: Well, you’re going to dislike me even more.
MR. JACKSON: You know I’m kidding, don’t you?
MR. BURR: I do. I can take it.
MR. JACKSON: Because this would be scandalous.
MR. BURR: Bill Parcells was one of my coaches. I can take it. That’s a true story.
MR. JACKSON: I believe you. That’s why I’m moving back. First of all, in my experience, any lawyer named Bubba is either 5’2” or 6’7”.
Denyce M. Sanders, RDR, CRR
And the $64 million question is…
Q. Now, is it your position that retainage is not a receivable?
Q. So did you plan on giving retainage to the buyer — to the seller?
MR. JONES: Form.
BY MR. SMITH: Q. Okay. Could you explain that, please?
A. Explain what?
Q. Your answer
A. To what?
Q. To the question.
A. Which question?
Q. My last question.
A. Can you repeat it?
Q. Sure. What were you planning to do with the retainage?
A. That was your last question?
Q. I’ve rephrased it.
A. Well, I’m confused now.
Q. Why don’t you just answer my question.
A. Because I’m confused.
MR. JONES: Which question?
BY MR. SMITH: Q. What are you confused about?
A. The question.
Q. Let’s start over.
Kelly Brokaw Sears, RMR, CRR, CRC
MR. SMITH: Officer Jones, the packet, it’s not leather. Is it cloth? I can’t really see.
OFFICER JONES: Canvas.
MR. SMITH: Canvas. So would you call that black or brown? I’m calling it black.
OFFICER JONES: I’m with you, counsel.
MR. SMITH: Oh, boy. We got problems. Who can help us? Black or brown?
THE COURT: Green.
MR. SMITH: Green? I’m not even close. See, I am color blind. Okay. Thank you, Judge. I appreciate that.
OFFICER JONES: But I didn’t charge him with that, for what it’s worth.
Punny lawyer alert
Q. What’s the last job that you had?
A. I was a sales rep for Owen Tree Service.
Q. Going out on a limb, but does Owen Tree Service do tree work?
What’s in a name?
(On cross-examination of an expert witness.)
Q. Now, you know Dale Webb [phonetic], I believe it is?
Q. Webb or Webber. I’ll get the name.
Q. He’s an expert on this, is he not? Whoever he is.
Jan Hunnicutt, RPR, CRR
Santa Rosa, Calif.
Old systems never die
Q. If you’d flip to the Bates number 2670.
A. What’s a Bates number? Can I ask that?
Q. So, Mr. —
A. It’s a new term for me.
Q. I apologize. I used to say that. You know the Dewey Decimal System was named after Dewey?
Q. Some guy named Bates put numbers at the bottom of a document. He will live forever.
Sandra M. Mierop, RPR, CRR, CRC