My awesome co-counsel and all-around cool person Carrie Lucas was taking the deposition of our opponent’s expert. Opposing counsel was objecting to pretty much every question, which was getting tiresome not to mention sort of coachy. Carrie decided to call him on it. Take it away, Carrie!
(BY MS. LUCAS) [Reads verbatim from expert’s opinion about a document in the case.] Do you know which document that is?
[OPPOSING COUNSEL]: Objection, beyond the scope and compound.
MS. LUCAS: I’m trying to understand how this is beyond your scope, Mr. [Opposing Counsel], given that I just quoted from her report. So can you please explain that objection so that I have an opportunity to try to fix it, given that I quoted from her report?
[OPPOSING COUNSEL]: I’ll withdraw the objection.
MS. LUCAS: Thank you.
[OPPOSING COUNSEL]: Actually, I’ll withdraw the beyond the scope. It’s still vague and compound.
MS. LUCAS: While she’s looking, if you could help me out on the vague objection, because I’m also not understanding how asking her to identify the document that supports her position is vague.
[OPPOSING COUNSEL]: It’s vague in that it’s compound. You’re asking her to look for the document to support her position for at least two or three different compositions.
MS. LUCAS: That would be a compound objection, not a vague objection, but I am happy to have all of the parts, if she can find any document that will support any of that.
Unfortunately, TextMap does not have an annotation option for “snorted my seltzer into the keyboard while reviewing.”
I can hardly believe what I’m hearing (reading). I am so glad this is recorded for posterity because no one would believe it. But anything Carrie does is believable and smart.