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I’m not sure how this will impact this bowl, but it is worth pointing out the need to assess whether there should be concern for those in this bowl. While we all understand ADHD is something attorneys are completely capable of managing with legal positions, not everyone in the field agrees with that. https://joinfishbowl.com/post_va66ztgmkw
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Wishes and prayers you get someone that uses an actual computer if it’s remote, and who knows how to mute/turn their screen off.
I had to ask someone to put their phone down so sue wouldn’t take the depo with her to the bathroom. So, good luck!
Practice! You can find friends or family to "volunteer."
I write out every question I want to ask, and then include supporting details underneath, references to specific documents to pull out if the deponent deviates from the expected answer, etc. After that, I try to divide the questions into sections, although there will always be some miscellaneous ones. Here’s an example:
What did you tell Dr. Johnson about your fall?
- on 6/7/20, plaintiff told Dr. Johnson she fell on her right side
- *contradicts incident report where she stated she fell on her left side.
And then I would have those medical records and the incident report in a binder, and it’s up to you to decide whether to press on any inconsistencies
Read and go about your materials several times. Or you can listen to calm music minutes before your taking of the deposition.
Rising Star
OP: how did it go?
Chief
Organize your topics by trigger words— short list of one word things that can get you back on track if you get lost midstream
Hello, OP! I just read this post. It's probably too late to give tips. Just here to ask how did it go?
Opposing counsel was “sick” and didn’t have a replacement attorney so we’ve rescheduled for mid January