My Photo
Blog powered by Typepad



« A Sample Motion in Limine: Plaintiff's Version | Main | The Rules of Evidence Applied to Presidential Debates »



I use the Ignore Strategy routinely, to deal with opposing counsel who are acting like jerks. Here's an example, keeping in mind that in my state (in state litigation) the only valid objections you can make during a deposition are "Form" and "Foundation."

UCL: Mr. Smith, why did you make that decision?

Counsel: UCL, I object. Asked and answered. We've already gone over this a hundred times and I think he's already answered the question. This is outrageous. You're somewhere out in leftfield right now. No not even that, you're in the bleachers. I've never seen anything like this before. Let's move on already!

UCL: Mr. Smith, why did you make that decision?

Counsel: [now sounding more angry] blah blah blah blah blah!!!

UCL: Counsel do you want to call the judge to intervene and decide whether I'm permitted to get a responsive answer to my question, right now, this very moment?

Counsel: I didn't say that.

UCL: So Mr. Smith, tell me, why did you make that decision?

[And Mr. Smith answers]

The comments to this entry are closed.



    How to Feed a Lawyer (and Other Irreverent Observations from the Legal Underground)

    Click on the book cover for details!

Search Trial Practice Tips