All of these comment’s about takeing depo’s are great, and I can NOT add alot to them. One thing NOT mentioned that I was told 3 thing’s by the manageing partner is — and this is a little bit sexist but onley applies to women like me when takeing the depo’s: These are that 1) when you are takeing the EBT of a man, wear nice clotheing that does NOT show anything, but can get him distracted enough so that mabye he will slip up; 2) The second rule is alway’s to schmoozze with both him and his legal counsil before the EBT, again to soften them up, and 3)the third rule is when you ask a question, look the deponent up and down (the way they do us on the street) and do NOT hesitate to cross and uncross our leg’s. Is this sexist? Of course, but does it work? Generaly yes, when you are dealing with a MAN. When you are deposeing a woman, another set of rules apply which center around 1) dressing very conserveatively, so as NOT to enrage the deponent or get them jelous that you are attractive; 2) always look them ONLEY in the eye — which can unnerve them and cause them to lose foccus, and 3) be courtyous to the woman when comeing in or leaveing, askeing her if she needs to use the ladie’s room, which you can show her.
There are alot of EBT’s I’ve done where they have made enough mistakes that I was abel to get a quick setttelment from rather then goieng to trial. But the most important thing is to RELAX and realise that whatever you forget about you can always clean up at trial, if they want to get that far. Most of the plaintiff’s I deal with are men and they nearly all wind up setteleing. YAY!
I have never heard these pointers being called out before on the male/female score, but they do make sense. I think we all have to use whatever powers we have to get to the result we want. If that means saying and doing things differently when we are interviewing men vs women, so it must be. It makes much sense to me. Of course dressing in a way that distracts the plaintiff cannot be a bad thing. If they slip up, you can always get them at trial with their depo testimony. Looking a woman (or man) only in the eye can be unnerving, and that could get the same result. Of course, since men always give us the once over, what's the harm in turning the tables and getting them on edge? All can help get the result we want, which is a slip up or two at the depos, which she evidently is able to get! GO GURL!
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