EP 720: Deposition Tips Part 3: Be the most prepared person in the room

Episode Notes

Transcript

Announcer [00:00:01]:
Welcome to The Jury Is Out, a podcast for trial attorneys who want to sharpen their skills and better serve their clients. Your co-hosts are John Simon, founder of the Simon Law Firm, Tim Cronin, personal injury trial attorney at the Simon Law Firm, and St. Louis attorney Erich Vieth.

Tim Cronin [00:00:21]:
Welcome to another episode of The Jury Is Out. I’m Tim Cronin.

Erich Vieth [00:00:24]:
I’m Erich Vieth.

John Simon [00:00:25]:
I’m John Simon.

Tim Cronin [00:00:26]:
We had started The last couple episodes, we started a series on deposition tips, and we covered considerations before you actually start thinking of the questions you’re going to ask, like what kind of style and approach you should have, brainstorming about what you want to accomplish, what your reason for the depo is, the goals you might want to accomplish. Where we left off and are going to start now is your actual, like, meaningful preparation. Once you figure out what you want to accomplish, start prepping. And we have Erich back now to help us fill in our inevitable gaps on the subject. So what we’ve put together here are 8 tips to be the most prepared person in the room. And you’ve probably heard me say this 1,000 times. I say it at CLEs, I say it to our law clerks. The best advice I ever got as a young lawyer, and even before actually, is whether you’re in a hearing, a trial, in a depo, anywhere, always try to be the most prepared.

Tim Cronin [00:01:23]:
prepared person in the room, and that certainly applies to a depo. So, John, I know you meticulously prepare for every depo, probably even more so than I do. I learned a lot of this from you. I start kind of back from scratch, going back first and reviewing the important pleadings again, especially if I haven’t taken a depo in the case in like, you know, a month or 2, and I might have forgotten some stuff. I go back and review, like, look at my complaint again and the key allegations. It might Tell me that I need to amend some things. Look at their answer. Any other key pleadings from key motions that have been argued? I review my client’s and the defendant’s written discovery answers again and then start reviewing the document production again.

Tim Cronin [00:02:06]:
Now, you can’t go back and review 500,000 or 1 million documents every single time. Jon, do you still keep a shadow file?

John Simon [00:02:13]:
You know, it is all about preparation. But one of the things is you got to decide who the witness is.

Tim Cronin [00:02:18]:
Yeah.

John Simon [00:02:18]:
And what you can do with them. And it’s so easy today with everything online. I mean, we know more about anybody before we even meet them just by all the stuff that’s online. But, you know, we were talking before we got started, Erich and I, about a case with 3 different experts on the same subject. And they were coming up for deposition. And my approach was completely different with all 3 because what I found out about their background, you know, one appeared to be extremely reputable and honest and straightforward. tremendous credentials and another one not so much, you know. And my whole approach was I knew that there were some things I was going to get out of some witnesses, other witnesses, you know, I wasn’t going to get a whole lot, you know.

John Simon [00:03:01]:
But, you know, the other thing, too, is you’ve said this before and I’ve said it before, is, you know, you do get information in depots, but the primary purpose of the depo isn’t just to get information.

Tim Cronin [00:03:10]:
It’s to make your case better.

John Simon [00:03:11]:
It’s to advance the case. Right. It’s to advance the case. And I see depositions sometimes where, you know, it’s okay. You got to ask open-ended questions in a deposition to get the information, but then you use that to pin them down a little bit. But all of that has to do with— what’s the saying that there’s no favorable wind to someone that doesn’t know the direction that they’re heading?

Tim Cronin [00:03:32]:
Yeah.

John Simon [00:03:33]:
I mean, if you don’t know where you’re going, there is no favorable wind. Right. And so you need to know where you’re going to start your preparation. What does that path look like? Where are you trying to end up in the case? And then as a microcosm of that, where are you trying to end up in this deposition? How does this witness help you get to where you need to get in the case?

Tim Cronin [00:03:57]:
And then you start your prep. Yeah.

John Simon [00:03:58]:
Right. And I actually, as a young lawyer, one time I had a deposition of an expert and I thought it was incredibly complicated. causation issue in the case. The other lawyer, who was much older than me, wasn’t real straightforward with me. I said, what’s this guy going to cover? And he said, just damages. Yeah. And so I, you know, very, you know, gullible. Foolishly believed him.

John Simon [00:04:21]:
Foolishly believed him. And I show up at this depot. I remember it was— it was on a weekend, on a Saturday or something. And they both were sitting there with big smiles on their face.

Tim Cronin [00:04:29]:
Yeah.

John Simon [00:04:30]:
Because as I said, it was a very complicated causation issue. And it was a chemical exposure. And all of a sudden this guy starts laying out all of these opinions that I was not prepared to address in a deposition. And I’m glad I learned that lesson very, very early on. It was like in my first, like second, third year of practice because I don’t go to any deposition. I don’t care if the person is a custodian of records. Yeah, I’m going to know what I need to know in the case and be prepared. Yeah.

Tim Cronin [00:04:55]:
Especially if it’s an expert, because you never know.

John Simon [00:04:57]:
Are you really wasting any time by preparing You know, if you have— it’s not going to be your only witness.

Tim Cronin [00:05:02]:
You’re going to address that issue with other witnesses.

John Simon [00:05:04]:
You’re going to address that issue with other witnesses. And so you might as well get it all down.

Tim Cronin [00:05:08]:
Look, I review all the discovery answers and all identified key documents that I keep in a shadow file above my computer in the case before every single witness I take, not just to figure out which ones might I want to use based on what I think the witness is going to say or cover, But in case they say something else, I’ve refreshed my recollection of all the key stuff.

John Simon [00:05:30]:
We’re in a different world now. I mean, with AI and the other thing, Erich and I started practicing before we had emails, right?

Erich Vieth [00:05:37]:
My first firm had no computers.

John Simon [00:05:39]:
No, we didn’t even have a fax machine. It was a new technology.

Erich Vieth [00:05:43]:
We didn’t have pencils.

John Simon [00:05:44]:
Right. Okay. But anyway, going into things and you’re like, you’re completely blind. You didn’t know what the heck the person, you know, what the person’s going to say. Nowadays, You know, with the email chain and most of our cases, the ones, you know, the ones I’m working on have a whole bunch of documents in them. And so, you know, you can do things like, I want all of the emails mentioning this individual in reverse chronological order by 6-month, you know, whatever. If you do it right, you should know way more about the subject matter than the person you’re deposing.

Tim Cronin [00:06:15]:
Yeah.

John Simon [00:06:15]:
And that’s usually the case, you know.

Erich Vieth [00:06:18]:
I’ll offer something and I have conversations with myself because I, you know, we all have a lot to do. And part of me says, well, I know what’s in the petition, or I know what’s in the answer. And because we forget a lot of stuff because we’re trying to remember a lot of stuff. I go back to something I did 6 months ago and I’m usually surprised about what’s in there. There’s always something in there that I’m not remembering.

John Simon [00:06:38]:
Yeah.

Erich Vieth [00:06:39]:
So there’s this moment where you just have to, you know, cajole yourself and say, no, go back and read it line by line. Because sometimes an answer, which is, usually formulaic, will have something in there that’ll give you a hint about where they’re going. And so review the pleadings again. You know, it’s like the last thing I really want to do. I want to get into the—

Tim Cronin [00:06:57]:
Yeah, I hate doing it, but—

Erich Vieth [00:06:59]:
Right.

Tim Cronin [00:06:59]:
Yeah.

Erich Vieth [00:06:59]:
And you just have to tell yourself, no, no, dig down and look at the whole thing again.

John Simon [00:07:03]:
Yeah. And, you know, now with, you know, as I said, the things are so document intensive, I always pre-highlight my exhibits. I get them lined up. I do this because I don’t put my own documents up on the screen. on my computer. I usually get a video tech from the video company.

Tim Cronin [00:07:18]:
Or somebody here that does it.

John Simon [00:07:18]:
Or somebody here that does it. Zach will do it. But I do this. And again, I’m not talking about an auto accident case. I’m talking about a case where, you know, I’ve got a depo in 2 weeks that literally there are going to be, you know, probably 500 different individual pieces of paper that are going to be presented at some point. What I like doing is not only will I mark them and get them organized, But I will meet with the videotek the day before the deposition and actually go through and I’ll—

Tim Cronin [00:07:48]:
How you’re going to use them.

John Simon [00:07:49]:
How I’m going to use them.

Tim Cronin [00:07:49]:
What you might blow up.

John Simon [00:07:50]:
Pull them up. What do they look like? I’ll highlight them myself. But, but and part of it is, you know, have you ever been to a deposition with a whole bunch of exhibits? Something always goes wrong. Yeah. You know, and I will tell you, every time I do a pre-run with the exhibits, it never fails. There’s always 3 or 4 things that weren’t there or we can’t find the page. I like running through it. And part of it too, it gets you thinking about the issues even more.

John Simon [00:08:13]:
Sometimes I pull the exhibits during that process. I’ll switch them around.

Tim Cronin [00:08:17]:
Well, you can always not use one and it’s not like it’s disclosed to the other side, right? But whether in person or remote, I pre-mark and highlight the key portions for every exhibit I intend to use. And I have a key documents folder of, of documents or exhibits I’ve used with other witnesses or may at some point that I have available to me, even if I didn’t plan to use it, I know where it’s at. I can go get it, I can pull it up. I keep a digital folder on my desktop and put everything in it I may need, as organized as possible.

John Simon [00:08:48]:
You know, the other thing too, and again, it depends if you got an auto accident with a police report, you don’t need to do this. But if you got a case that’s a little bit more involved, what I do, and like we were saying, most of the cases you’re going to take you know, a dozen depositions or more.

Tim Cronin [00:09:02]:
Sometimes 80.

John Simon [00:09:02]:
Sometimes 80. But a few of those cases— What I do is I create my outline and I always have a— I always prepare a written outline, you know, mostly a typed outline.

Tim Cronin [00:09:12]:
Yeah.

John Simon [00:09:12]:
And in the beginning of that outline, Tim, you’ve seen this, I have a case summary, I have an index to the outline, and then I go into a case summary. And it’s pretty much the same with all the cases. The first page is the parties, the attorneys, you know, that kind of information, information about the incident, the date, all of that kind of stuff.

Tim Cronin [00:09:28]:
I have a one-page summary of the key facts and issues in the case.

John Simon [00:09:32]:
I have more. I go— I kind of go overboard. But one of the things that I put in there are a timeline. Yeah, I’ll put terms if it’s a case that’s real heavy into the medical issues, if it’s in— if it’s some kind of like a radiation exposure case or if it’s, you know, carbon monoxide level in the blood, that kind of thing. I put— I’ll put a list of just terms so I can have them available. And, you know, here’s the thing. If you prepare it, you don’t use it. I prepare that summary and just the process of preparing it, putting it together, I never look at it, you know, but it’s nice to have it if something comes up.

Tim Cronin [00:10:08]:
Yeah. Unless you have a little dispute about a term. So, I mean, that brings up the exact next point, which is research the technical issues that may be discussed, medical terms, engineering concepts, literature on point. And I do the same thing. I have definitions of key important terms. that I have at the beginning of my outline, even though I know them, in case there’s some like, well, what do you mean by that? And then I’ll go back and go, here’s what I mean. Do you agree that’s what that term means? So you got to research all that stuff to the point you already made— understand the subject matter, or the witness can talk circles around you on challenge.

Erich Vieth [00:10:42]:
Is this important, or is this just me, you know, hallucinating? I think if you look like you are in total command of the subject You’ve got your glossary of terms, you’ve got your documents all marked, everything’s ready. It just, it shows that you’re serious. And I think the witness might respond differently.

Tim Cronin [00:11:02]:
They respond entirely different.

Erich Vieth [00:11:03]:
Knowing that you absolutely— when they, when they veer off course a little bit on something, they cheat a little bit, you bring it back in right away.

John Simon [00:11:11]:
I got news for you. The witnesses, especially the professional witnesses, they research us. And they look you up. They know, you know, who you are. Well, and the lawyers tell them about us. And the lawyers tell them about us. And, you know, with me, if I’ve got somebody who’s going to be a problem, I try to establish very early on that, you know, the questions are going to be answered. Questions are going to be my questions.

John Simon [00:11:32]:
Yeah, your questions are going to be asked. They’re going to be my questions, not anybody else’s questions.

Tim Cronin [00:11:36]:
Okay. I’m not here to find out what you’re going to say to what they’re going to ask. I’m here to find out what you’re going to say to my questions.

John Simon [00:11:42]:
Bottom line is you got to be prepared to go different ways in the deposition. because you really don’t know what you’re going to encounter most of the time.

Tim Cronin [00:11:50]:
And something I didn’t used to do earlier in my career because I just thought, you know, we hire experts, we take all the— we take all the fact witness depos or the defendant doctors or the corporate reps, and then we take that info and we give it to our expert and then we put them up for a depo. And I wasn’t utilizing them as much. I’ve started to much more utilize my experts throughout the process, even initial discovery, like what kinds of things can I ask for? And for key depos, I will schedule a call with, you know, my neurosurgeon or whoever it is that obviously they’re good.

Erich Vieth [00:12:21]:
Sure.

Tim Cronin [00:12:21]:
And say, what can I ask and how that’s going to kind of pigeonhole this person to not be able to give some kind of crazy answer that’s going to help you down the line? So I schedule calls with an expert a week in advance to ask questions, ensure I understand their thoughts and opinions, the issues that will be discussed. That’s what you’re paying them for. I mean, if you’re not using them, why are you hiring just to be a mouthpiece later on the stand?

John Simon [00:12:45]:
You know, use them. So the other thing, too, you were talking about terms. Well, not just for, you know, scientific terms, engineering terms, medical terms, you know, those kinds of things. But a lot of times, you know, you might have a handful or one or more, you know, unique legal issues in the case, you know, like what’s a joint venture, you know, what are the elements of that, or agency and how that’s defined under a new statute where, you know, they’re using it to affect whether you can submit on punitives against, you know, an employer.

Tim Cronin [00:13:17]:
Or you’re in a jurisdiction you’re not usually Yes.

John Simon [00:13:19]:
You don’t already know. And so what I do all the time is I’ll find a case that’s supportive on point, and I will take the exact language from that case. I will formulate my questions with it. You know, if it’s an issue about agency, if it’s an issue about partnership, if it’s about here, contributed to cause, right? Not all the states are the same, but that’s so helpful because then, you know, fast forward in 18 months, you’re standing at the sidebar and they’re saying, well, you know, we want to throw this claim out because they haven’t made a case under whatever, you got the question, you know, exactly what’s the law. Here’s the case. Right.

Tim Cronin [00:13:54]:
Here’s the case.

John Simon [00:13:55]:
Here’s the law. Here’s another. Let me ask you guys this. This is something that, that I’m struggling with now. And AI to me, I mean, we’re not going to spend all day talking about AI, but it’s so easy. You want to take somebody’s depo? Great. You got a case, a lot of documents. Great.

John Simon [00:14:09]:
Go down, sit down and have Claude prepare a cross-examination or depo outline for you. Print it out and go to the depo. Okay. And there’s something, you know, fundamentally wrong about it. It’s very helpful.

Tim Cronin [00:14:19]:
Yeah, but it’s a great tool.

John Simon [00:14:21]:
It’s a great tool. But what I see is if I do that and I’ve done that before, I’ve not just used that outline, but just to kind of get a start. If it’s not my outline, if I didn’t create it, it’s not helpful. You know, you really need to— you need to understand it.

Tim Cronin [00:14:36]:
You’re prompt of what you want. So I am using it increasingly. But as a very valuable tool, but I use in addition to everything else I already did. So all of the brainstorming things we talked about in the prior episodes— what do you want to accomplish with this witness? What do you think they might want to address? I do all of that. I have a project that’s created that Claude has access to review stuff with the key documents in the case and other depos and all that stuff. And I very carefully think out my points. prompt to say what I want to address with this witness, traps I may want to set, and how I want it organized. Like, it’s a long prompt.

John Simon [00:15:14]:
That’s what I do. I organize it myself.

Tim Cronin [00:15:17]:
Yeah.

John Simon [00:15:17]:
I’ll even say, what are the issues? To make sure I’ll make an issue list and I’ll say, what are the issues? Then I’ll get that and I’ll reorganize those issues. I’ll break some apart. I’ll get rid of some of them. They will get me thinking about yet another issue. And then what I’ll do is I go issue by issue and then I will write out my questions and then I’ll ask, I’ll run it through and say, how can I phrase this better? How can I tighten this up? What are some alternatives? What are some alternatives? And it’s usually 9 times out of 10, it’s how do I shorten this? You know, I’ve got 12 questions. I want 4 good ones, you know? It’s been a big help for me in actually formulating the specific words in the questions.

Tim Cronin [00:15:57]:
So I do that. And then once I get the work product, I also say, ask me any questions to help complete this project. And then once I formulate, like, and get the outline that’s spit out and I have it say, you know, citations to particular documents or what other witnesses have said, I then spend the same amount of time as I would when I used to just create them from scratch going through. And this is the last part of our prep section is make an outline. The more detailed, the better. Don’t just stare and read the questions one after another. It’s there if you need it, but. It’s so you don’t forget something and we’ll talk about more.

Tim Cronin [00:16:31]:
But I then take that and I still have all my key documents next to me and I go through them again and I go through every single word in that outline that spit out again and we’ll change stuff, figure out if I want to move stuff around, phrase things differently. So it’s a great tool to be used, but it’s not something to just go like, that did the job for me.

John Simon [00:16:53]:
Because, you know, you got to think because you’re going to encounter things in that deposition that you’re going to need to respond to.

Tim Cronin [00:16:59]:
Yeah.

John Simon [00:16:59]:
And Claude ain’t there, you know, giving you the answer to the question. You got to figure out what the hell’s going on.

Tim Cronin [00:17:04]:
Yeah.

John Simon [00:17:04]:
But the other thing is you really do like going into a deposition. How many times have you ever prepared an outline and you went through that outline from beginning to end in the exact order that you wrote that outline? Never. Yeah, it’s never happened to me because one of the things we do in depositions is we try to listen.

Tim Cronin [00:17:22]:
Yesterday I did because the man said yes to every question, as I told you.

John Simon [00:17:26]:
But I was like, I was like, whoa, somebody’s playing a trick on me. I think the best, the best thing you can do in the deposition, you know, other than prepare, is you got to be a good listener. And by listen, I don’t mean just closing your eyes and listening to the words, but look and listen to what’s going on in that room. Here’s the terrible thing about Zoom. I get so much information about my case, about the witness, about the issues by watching the response of opposing counsel in a deposition when I ask questions.

Announcer [00:17:54]:
Yeah.

John Simon [00:17:55]:
Now, some of them are wonderful because They let you know exactly when there’s something important because they yell out an objection. And on Zoom, a lot of times that’s gone. You’re not in the room together.

Tim Cronin [00:18:05]:
I mandate that if I’m taking a Zoom depo, if opposing counsel is there with the witness or the remote, that they be on a separate screen. I make that— I tell them in advance.

John Simon [00:18:16]:
Yeah.

Tim Cronin [00:18:16]:
I say it’s not— I have the rule. I’m not like accusing you of anything, but if we were in person, I’d be able to see you and I require that you have your own laptop there if you’re next to your client or your expert. And so I can see you just like you can see me. And I don’t, I don’t get any pushback on it because it’s incredible.

John Simon [00:18:35]:
When do you do that? Do you put it in the notice?

Tim Cronin [00:18:37]:
In advance of the depo, I talk, I talk to the—

John Simon [00:18:40]:
That’s a great idea. I don’t do that.

Tim Cronin [00:18:42]:
And I don’t have Zoom depots just pinned on the witness and that’s all I can see. I keep all the windows up.

John Simon [00:18:47]:
It’s amazing. I did that a couple of times and it was frustrating to me because I wanted to see the witness better. I wanted to concentrate on the witness. My thought at that time was, I’ve got to give up looking at the other attorneys because I really want to engage and connect with that witness.

Tim Cronin [00:19:04]:
The new platform we’re using, which you were going to use Saturday, but the depo got pulled down, it’s called Remote Legal. It allows you to simultaneously pin the witness so they’re on a bigger screen to the left, but the other windows are to the right.

John Simon [00:19:18]:
So that’s a good idea.

Tim Cronin [00:19:19]:
So you can still see opposing counsel. And the court reporter, and the court reporter can see everybody.

John Simon [00:19:24]:
So it’s not just what they’re saying, but how they’re sitting. It’s their nonverbal communication, right?

Tim Cronin [00:19:31]:
Not just what you say, right?

John Simon [00:19:32]:
It’s how you say it, your, your mannerism, your tone of voice.

Tim Cronin [00:19:36]:
And as you go, you got to focus on the witness while you’re engaged on a topic. You have your outline to make sure you didn’t miss anything or for reference when trying to rephrase something the way you figured out ahead of time.

Erich Vieth [00:19:47]:
Can I go back to the outline?

Announcer [00:19:49]:
Yeah.

Erich Vieth [00:19:49]:
I think there’s something that I’ve noticed. Let’s say you let Claude do an outline for you. I think it occupies your attention, and it’s hard to think of the things that you would’ve thought about had that not been in front of you. So I’ll have AI maybe throw out topics, but I’ll use that as a checklist. I wanna go first. I wanna let my brain think, okay, what would I do? Because I think I’ll miss things if I’m looking at a sheet of paper that’s got ideas on it. And same thing for—

Tim Cronin [00:20:18]:
it’s why, yeah, I write all my ideas and what I want to do first.

Erich Vieth [00:20:21]:
Yeah, yeah.

Tim Cronin [00:20:22]:
I also plug in my outlines from the other witnesses.

Erich Vieth [00:20:25]:
And this goes for me too. So if I make part of the outline like 2 weeks ago and then I didn’t finish it and I’m coming back to it, I don’t want to look at what I already did because then that’ll occupy my head. Like, oh yeah, I got all these ideas. I want to look at blank paper again and think, okay, what do I need to do here?

John Simon [00:20:41]:
I think it’s terrific at Organizing information. A lot of times I had a case where recently where I wanted to show a company’s expertise in a certain area. In other words, they knew about the subject matter. It was important for me to establish that. And they started talking about how they were a pioneer in it. And my Claude questions were, they were the first one to do this and the first one to do that. And I said, it sounds like we need to give them an award. I’m suing them.

Erich Vieth [00:21:07]:
That’s good.

John Simon [00:21:09]:
But, you know, it was literally what I asked for, but it was harmful if I ended up using it because I was like, no, no, it’s exactly what I asked for, but it makes them look like they need to be given an award for being an industry leader in something. You know, that’s not why we’re here.

Erich Vieth [00:21:24]:
I’d like to offer something also on how I prepare the outline. If I were to use— I’ve gone to blank paper now. It’s just my rebelliousness. If I start writing ideas, it becomes this mess of handwriting and, and then there’s arrows and boxes and all that stuff. So what I’ve done is I use, it’s a view in Microsoft Word, it’s called Outline View, and it allows you to create an outline with demoted and promoted sections of ideas. So you can make an outline like A, B, C, and then A—

John Simon [00:21:56]:
Scroll around.

Erich Vieth [00:21:56]:
Small one. And if you’re thinking, oh, that subsection doesn’t go there, the subsection goes, you drag the whole subsection. So I’ve used this for like 10 years. It’s a really nice feature for brainstorming. And then you can copy and paste sections of depositions from prior depositions. And, uh, of course, once in a while you actually write a question. Like sometimes you’re thinking, this is going to be a critical moment and I want to actually ask it about the other jurisdictions might have a particular way to phrase that thing. And then I’ll have that.

Erich Vieth [00:22:28]:
And Quite often when I’m reviewing the depositions, I’m going, yeah, that was a good question. And I’m— and I think, yeah, I wrote that one down. That was— it had to be exactly the right way. And these outlines grow big. Then you can hide subsections if you want. So it, it might look unwieldy, but you can say, I’m going to start with Section 1, blow it up, and then you’re looking at it. So it’s a, it’s a nice tool, and I haven’t found something that would be better for me than that so far.

Tim Cronin [00:22:51]:
All of my outlines have sections. It’s not just a list of questions. It’s like the Roger Dodd chapter method, which we talk about, but I have things in sections with big bold headers so that if I get ahead of myself or the witness goes somewhere, I know where to flip.

John Simon [00:23:06]:
That’s what I do. See my depo outlines? I break down the sections. What I do is I have just— I’ll have a section I want to talk about, one section like destroying documents or whatever, and I may break that up into 5 parts or 3 parts. And then what I’ll do is just make those each a heading and, and kind of flow with that. I’ve typed my outlines for years, and I go through them and change them and revise them. I go through them a dozen times probably in most depots.

Tim Cronin [00:23:35]:
I do a little less than a dozen, but I spend a lot of time on it.

John Simon [00:23:38]:
Yeah, and I take some stuff out. I— yeah, and then, you know, part of it too is you got to have the outline and be prepared for all of these different issues. Most important, once that depot starts, you need to be a really, really terrific listener. an observer to find out where they’re going. Sometimes the way they answer a question, just the way they answer it, the words they use, give you a clue how to rephrase it to get them off of it.

Tim Cronin [00:24:03]:
And that brings us to the next section, which is during the deposition.

John Simon [00:24:07]:
Really? I didn’t even read the section.

Tim Cronin [00:24:10]:
Which we will do on our next episode. So join us next time. This has been another episode of The Jury Is Out.

Erich Vieth [00:24:16]:
I’m Tim I’m Erich Vieth.

John Simon [00:24:18]:
I’m John Simon. We’ll see you next time.

Announcer [00:24:23]:
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