Flattery will get you everywhere
Q. All right. Was she a young woman?
A. Probably somewhere around my age.
Q. So a young woman?
A. Yeah. Oh, good one.
Don’t twist my arm
THE WITNESS: And so my husband and I were getting married in June. And I said, “I am getting this thing fixed before we get married because I don’t want to be walking in with my arm in a sling because everybody is going to say you twisted my arm and married me.”
Q. And since we talked a little bit about athletics off the record at the start of this deposition, I’m a little curious as to how one goes to Yale as an undergrad and Harvard for medical school, and where does one sit during The Game.
MR. SMITH: You’re under oath.
A. I tend to sit on the Yale side, but I haven’t gone in a while.
Q. The good answer would be either the home team side or whoever has the best tailgates.
Virginia Dodge, RDR, CRR
Don’t sit downwind
MR. JONES: Michael, your dog has gas.
MR. SMITH: Yes.
MR. JONES: May the record reflect that Michael’s dog has gas. I don’t need coffee anymore.
MR. SMITH: I would hate to have to validate or invalidate that assumption, but…
MR. JONES: The south end of your north-facing dog is facing me.
MR. SMITH: Yes, the south end of the dog is facing Mr. Jones. And it’s a direct hit, I have to say.
MR. JONES: You sunk my battleship.
MR. SMITH: That’s the kind of luck you’re going to have this week, Mr. Jones.
MR. JONES: I start a trial next week. You don’t need to tell me that.
MR. SMITH: Hmm. You may have to take a shower before you get there.
Gotta be from somewhere
Q. Dr. Green, you grew up in Dumas, Texas?
A. Yes, sir.
Q. When was the last time you were out in Dumas?
A. It’s probably been a couple of years.
Q. Do you consider yourself to be one of the Ding Dong Daddies?
MR. SMITH: He’ll know what that means.
MR. JONES: Yeah, I don’t know.
MR. SMITH: You’re not from out there?
Therese J. Casterline, RMR, CRR
The Colony, Texas
Q. Have you ever been in a deposition before?
A. No, I never have. I don’t know how I’ve avoided it.
MR. SMITH: Carefully.
THE WITNESS: Carefully, yes.
MR. JONES: So that’s a good thing.
Q. Do you mind just starting that answer again a little bit slower?
A. I’m sorry. Yes.
THE COURT: See the nice court reporter?
THE WITNESS: Yes, your Honor, I do. She’s very lovely. By the way, I love the scarf. I will slow down.
THE COURT: Then don’t kill her.
THE WITNESS: I will not. I will not. I promise. Mea culpa.
THE COURT: It’s accepted. But you be true to your word and speak slowly.
THE WITNESS: Yes, ma’am.
Lisa Edwards, RDR, CRR
Location, location, location
MR. JONES: Okay. And, for the record, she’s used her right hand and put it directly below her neck, right at her chest.
MR. SMITH: Actually, it was by her heart, your Honor.
MR. JONES: Okay. That’s fine.
THE COURT: Okay. With that important distinction on the record, we’ll accept that modified stipulation, Counsel.
As long as you’re not hangry
Q. As you sit here today are you feeling impaired in any way that would affect your ability to testify about past events?
A. No. A little hungry. But…
Helga Lavan, RPR
Oh, the fear I instill!
A. Yes, ma’am.
Q. Did I read that correctly?
A. Uh huh. Yes, ma’am, you did. I’m sorry. I said “uh huh,” and I want to make sure I got it straight.
Q. Thank you for catching that.
A. I didn’t want Denyce to get me.
Q. That’s fair.
Denyce Sanders, RDR, CRR
What’s the diff?
Q. Tell me about that carpet.
A. It’s a rug.
Q. What’s the difference between a rug and a carpet?
A. Carpet is wall-to-wall. Rug is a piece.
Q. I’ve always had this picture of a flying carpet, and that’s not wall-to-wall.
MR. JONES: See, that’s where lawyers get their information — is from cartoons.
Cassy Kerr, RPR, CRR, CRC
The secret lives of pets
Q. Do you own any pets of any kind?
Q. Tell me about that
A. I own a rabbit, a cat, a snake, and three fish.
Q. Did you ever have a dog as a pet?
Q. Did you ever have any issues with that dog?
Q. Did that dog ever bite you or growl at you or attack you?
Q. Same question but for any other dog?
Q. Prior to the accident that we’re here for today, were you ever attacked or bitten or scratched by any other dogs?
Q. This may be a silly question, but I’ll ask the same question for the rabbit, the cat, and the snake. Did you ever have any issues with any of those pets?
Q. Where they attacked you or bit you or scratched you, anything like that?
MR. SMITH: What about the fish?
Q. I’m going to give the fish the benefit of the doubt. They’re not piranhas; right?
Kelly Palazzi, RPR
South Hackensack, N.J.