well I'm a little nervous this is my first deposition alone even though I've
well I'm a little nervous this is my first deposition alone even though I've

defended depositions and I've also sat in on some senior partners that have
defended depositions and I've also sat in on some senior partners that have

taken depositions but it's my first time in the lead and first time alone and I
taken depositions but it's my first time in the lead and first time alone and I

think I'm ready now all I have to do is execute good morning welcome to Boston
think I'm ready now all I have to do is execute good morning welcome to Boston

I'm James Dowling the third but you can call me Tripp and this is John Smith the
I'm James Dowling the third but you can call me Tripp and this is John Smith the

client good morning Tripp good morning John my
client good morning Tripp good morning John my

name is Elizabeth Jones and you can call me Liz
name is Elizabeth Jones and you can call me Liz

well Liz it's wonderful to meet you I hope you're enjoying our wonderful city
well Liz it's wonderful to meet you I hope you're enjoying our wonderful city

too bad about the weather yes I understand it's been unseasonably
too bad about the weather yes I understand it's been unseasonably

cold indeed how long have you been practicing I'm a third-year associate
cold indeed how long have you been practicing I'm a third-year associate

well good for you it seems like I was a third-year a hundred years ago
well good for you it seems like I was a third-year a hundred years ago

well welcome shall we get started yes why don't we please state your name for the
well welcome shall we get started yes why don't we please state your name for the

record my name is John Smith thank you now mr. Smith have you ever given a
record my name is John Smith thank you now mr. Smith have you ever given a

deposition before no well do you know how a deposition works sort of well mr.
deposition before no well do you know how a deposition works sort of well mr.

Smith I'm gonna ask you a bunch of questions about the accident and you'll
Smith I'm gonna ask you a bunch of questions about the accident and you'll

have to answer them under oath mr. Dowling is also allowed to ask you
have to answer them under oath mr. Dowling is also allowed to ask you

questions if he so chooses there's a court reporter here that will be taking
questions if he so chooses there's a court reporter here that will be taking

down everything that is said here and that will get turned into a transcript
down everything that is said here and that will get turned into a transcript

if you want to you can review the transcript and make sure it's accurate
if you want to you can review the transcript and make sure it's accurate

and make any Corrections before signing it do you understand
and make any Corrections before signing it do you understand

yes all right then let's get to it are you currently employed by VIP
yes all right then let's get to it are you currently employed by VIP

engines yes and how long had you been employed by VIP engines at the time of
engines yes and how long had you been employed by VIP engines at the time of

the accident I think I started working there in 2006 so October 2006 I think
the accident I think I started working there in 2006 so October 2006 I think

okay so it was roughly about five years give or take object to form
okay so it was roughly about five years give or take object to form

can you please restate and rephrase in a different way yes of course do you
can you please restate and rephrase in a different way yes of course do you

remember the date of the accident I'll never forget that day November 19 2011
remember the date of the accident I'll never forget that day November 19 2011

okay and you started working at VIP in October of 2006 correct yes can you
okay and you started working at VIP in October of 2006 correct yes can you

please state your title at VIP engines at the time of the accident I was
please state your title at VIP engines at the time of the accident I was

manager of the southeast sales division thank you and can you please describe
manager of the southeast sales division thank you and can you please describe

the nature of that role dear I really think you need to think about these
the nature of that role dear I really think you need to think about these

questions I again object to form have you considered rule
questions I again object to form have you considered rule

26 what's his problem I may be overreacting here but he's
26 what's his problem I may be overreacting here but he's

objecting to really basic questions here rule 26 I don't see where he's going
objecting to really basic questions here rule 26 I don't see where he's going

with this at all am I overreacting I'll rephrase when you were working as the
with this at all am I overreacting I'll rephrase when you were working as the

manager of the southeast sales division what were your key responsibilities well
manager of the southeast sales division what were your key responsibilities well

pretty much everything I was in sales so everything that was related to that well
pretty much everything I was in sales so everything that was related to that well

could you be a little bit more specific what I'm looking for is to get a sense
could you be a little bit more specific what I'm looking for is to get a sense

of the tasks you are doing on a day-to-day basis
of the tasks you are doing on a day-to-day basis

so maybe we can start there could you maybe run through a typical day at the
so maybe we can start there could you maybe run through a typical day at the

office you know we're having a really hard time
office you know we're having a really hard time

following you honey can you slow down a little bit so we can all understand what
following you honey can you slow down a little bit so we can all understand what

you want from mr. Smith okay I thought I was imagining things but I
you want from mr. Smith okay I thought I was imagining things but I

think what's happening is pretty clear he's making his objections sound helpful
think what's happening is pretty clear he's making his objections sound helpful

and instructive but really he's trying to throw me off my outline and I think I
and instructive but really he's trying to throw me off my outline and I think I

have the feeling that it is because I'm young I'm a woman and not from this
have the feeling that it is because I'm young I'm a woman and not from this

jurisdiction what do I do
jurisdiction what do I do