Field Trip!

I don't know why this post wasn't ever written. I wrote a title and apparently saved it as a draft but then never actually wrote the post.

In January I got to take a field trip to Winnemucca for some depositions. And I got to take one of the depositions in the afternoon. I think I'm getting better at it. I still got a little flustered when opposing counsel objected and fumbled a little as I tried to clarify my question, but other than that I think it went well. The guy I was deposing was an older italian guy, so he had this really thick italian accent. I'm normally good with accents, but he spoke quietly and the air conditioning duct was right over my head so it was hard to understand him at times. It was great though because the defendant had claimed that they didn't have any documents to produce and so they didn't give us anything. Then we show up at the deposition and they magically produce this document that should have been disclosed. Opposing counsel claimed it wsa the first he had ever seen it. Then when I was deposing my witness he's like 'Oh yeah, we keep records and here's where you can find them." BUSTED! Opposing counsel was quick to say that this was the first he had ever heard of it and that they would get right on producing them. In other words, please don't file a motion for sanctions.

Then there was a deadline in february for them to respond to some discovery requests we had sent. I kinda dropped the ball on following up because I was sick and then missed those days to go to the wedding, so I sent a letter this week saying if they didn't respond, we'd move to compel production and request sanctions. Yay for being an attorney!