This deposition was in quite a different locale from the last. While last time I was in a small, windowless conference room that seemed about the size of a crackerbox, this deposition was in a beautiful, large conference room in a downtown law firm's office. "Now, this," I thought to myself, "is where I was meant to be!"
My host reporter's name was Paula. I had not put it all together, but after meeting her and speaking with her for a bit, I felt a bell stirring in my head. I think she had the same bell, and pretty much at the same time we started saying, "Didn't I see you . . . ?" and "Have you ever . . . ?" It turned out that A) Paula had seen me at the GWSRA convention in the spring, but B) Paula had worked on one of my cases when I was a paralegal, and we had had some friendly conversations "back in the old days." After that, of course, it was like old home week!
It was fun seeing Paula set up. She's a very experienced writer -- 31 years, in about every phase of reporting possible -- and she regularly brings her laptop on assignments for realtime translation. I hadn't seen a notebook set up since David did it at my very first hearing.
As we each prepared in our own way, the attorneys entered. There was the attorney taking the deposition. Then the attorney for the deponent individually. Then the attorney for the deponent as a corporation (since that was the capacity that he was testifying in). Then another attorney. Yikes! This was a bankruptcy hearing, so there were a lot of interests involved.
But the biggest "yikes" was when the deponent arrived. "Goodafternoonit'sgoodtomeetyou." Oh my gosh. But, well, he'll be slower testifying, won't he? Won't he?
My first mistake, I realized, as the deposition started, was not adjusting my position when the other attorneys arrived. I had taken a position between Paula and the witness. Unfortunately, that meant that I was on the same line as not only the deponent and his attorney, but also, as it happened, another of the attorneys, with the third attorney at the other end of the table. When I heard an objection, I didn't have the line-of-sight necessary to tell who exactly was objecting.
Fortunately, within the first five minutes the witness was reviewing a lengthy document, so I quickly got up, grabbed my machine, and hustled around to the other side. Because there wasn't enough room for me to settle down between the questioning attorney and Paula, the speakers were once again on the "wrong" sides for my banks, but that could be compensated for; lack of knowledge of the speakers could not.
In a way, though, it was all moot. The deponent in no way had slowed down during testifying -- in fact, he seemed to have speeded up, and taken the questioning attorney with him! I used every phrase I saw, came up with brief forms faster than I ever had ever! But to no avail. I was simply in over my head.
Mercifully, the deposition ended after an hour and a half (it had originally been scheduled for five hours!).
Afterwards, I asked Paula if she'd be willing to have a cup of coffee or something with me, and we ended up having lunch at Subway in a nearby food court. It was very interesting to hear about her early reporting experiences, and her current impressions of the industry. As many freelancers do, she works for a couple of different agencies. One of them is a large national firm that had taken over one of the smaller places she used to work for, and she seemed quite pleased with them. They were able to offer benefits like allowing her to purchase new equipment and then gradually repaying out of her earnings (instead of her front the money at the beginning).
Lessons Learned:Just like some depos are achievable -- some are not! (Or, to put it another way -- 225 is just the beginning.)
Judge agencies based on how well they fit your needs, not according to stereotypes of "smaller firms are unprofessional" or "large firms are greedy."
Don't forget about location -- if you can't tell who's speaking, you can't record the deposition properly.
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