What more is there to say
Q. Okay. How did you come to have a daughter?
A. The usual way.
Mary Seal, RDR, CRR
THE COURT: Before counsel asks you another question, where did you receive your bachelor’s in history?
THE WITNESS: University of the Pacific.
THE COURT: Do you have a brother Ross?
THE WITNESS: Yes.
THE COURT: Have you ever worked with my wife?
THE WITNESS: Yes.
THE COURT: Okay. She’s not the accountant for —
THE WITNESS: No.
THE COURT: We’ve never met though, have we?
THE WITNESS: We were in a class together, but you wouldn’t remember it.
THE COURT: I won’t take that personally. There’s a lot of college I don’t remember. What class was that?
THE WITNESS: Constitutional law.
THE COURT: Okay.
MS. BROWN: “Constitutional law.” That’s classic. Well set up.
THE COURT: I remember that class. I don’t remember you in that class. I remember your brother. Okay. But we don’t know one another.
THE WITNESS: That’s right.
THE COURT: As you were testifying, I recollected I’d heard your name in conjunction with accounting stuff. So I just want everybody to know about that. Perhaps we will find out about it later. I didn’t realize we were in class together.
MS. BROWN: I just hope we have no constitutional law issues in this case, Your Honor.
THE COURT: Yes. And that was only a couple years ago that we took that class. All right. With that trip down, memory lane, Ms. Brown.
MS. BROWN: Thank you, Your Honor.
Jan Hunnicutt , RPR, CRR
Santa Rosa, Calif.
A. No. I’m not aware that I’m limited to that. But —
Q. Are you seeking — well, go ahead. Were you going to say something?
A. I withdraw my “but.” From the room.
Q. The “but” is withdrawn.
Jennifer Honn, RPR
Easy come, easy go
Q. Then we can move on to income. Do you know how much you make in a year average?
A. I just work.
A. I’m a guy.
The (non) retirement plan
Q. Before this incident happened in January of 2015, what was your intention in terms of your remaining work life? How much longer were you going to go?
A. Oh, up until lunch time at my funeral. I mean —
Q. When was your funeral going to be?
A. Exactly. Exactly. As long as I could.
Sarah J. Dittmer, RPR
Lost in translation
The witness is being deposed about a car accident through a Spanish interpreter.
BY MR. SMITH:
Q. Can you compare the impact to anything else you’ve felt in your life?
Q. Sometimes people will tell me they played sports growing up.
Q. How about did you ever go to the fair and do the bumper cars?
A. I’ve never been on them.
Q. There’s nothing you can think of to compare the forces to?
Q. What about have you ever been on a roller coaster?
Q. Mierda? Does that mean scared?
MS. JONES: No. It means shit.
MR. SMITH: I didn’t know that. That’s funny.
Here, let’s go off the record for a second.
(Discussion held off the record.)
BY MR. SMITH: (continuing)
Q. Now that I’ve shown you how poor my Spanish is, I’ll keep speaking English.
The true cost of your time
There were 13 attorneys in attendance at this deposition of an expert witness:
Q. And then the total repair cost of 13,241
MS. WHITE: 13 million.
Q. (BY MR. BLACK) Let me try that again. I like my number better, but let’s go with the 13 million.
A. I think 13,000 is the hourly cost of this deposition.
Carrie Arnold, RPR, CRR
That’s a new tactic
WITNESS ATTORNEY: Same objection.
THE WITNESS: Objection.
Q. BY TAKING ATTORNEY: You — I’m not asking you about what you talked about with your attorney. I’m just asking if you talked to anybody else about the lawsuit.
Q. You’re –
A. I don’t know what I’m doing.
Q. — required to answer.
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