Depositions in Virginia…

What To Do When… Depositions Happen.

What To Do When Legal Chat Podcast... As Seen on the News from Critzer Cardani PC

WTDW Podcast | Episode 25: What To Do When… Depositions Happen.

Intro 0:01
Welcome to What To Do When….A podcast from real lawyers with real perspective, where we explore a variety of legal issues and scenarios. Each week we focus on a new topic and discuss What to do When, and if any of these legal scenarios ever happened to you or a loved one. With over 40 years of combined legal experience, our hosts offer their unique perspectives and insights on a range of real life legal situations.

Jackie Critzer 0:28

Hi, and welcome back to What To Do When…a podcast here at Critzer Cardani in Richmond, Virginia. I’m Jackie Critzer. This is Scott Cardani.

Scott Cardani 0:37

How you doing? Jackie, what’s on the docket for today?

Jackie Critzer 0:41
Today we’re talking about What To Do When… Depositions Happen.

Scott Cardani 0:45
Depositions. What are the depositions?

Jackie Critzer 0:48
It’s a big fancy word right here and and all the TV shows the legal TV shows or depositions this that and it’s sort of this big to do. But that’s a great question. What are depositions?

Scott Cardani 0:59
You know, they’re kind of like an attorney’s chance to ask all the questions he ever wanted to ask prior to trial. And there are a way to get this what we call discovery information about the case. So it’s a chance to either get one of the parties, if you don’t own a party is like, if Jackie and I are in a divorce, she’d be one party and I’d be the other party. So it’s the two people in the lawsuit or the two companies in the lawsuit or whoever it may be in the lawsuit. So you have that aspect. So and then you have potential witnesses in that trial. So discovery is a chance to kind of get a verbal take, because we often do written discovery answers and questions. And sometimes this is a way to follow up on those questions you ask. And sometimes it’s just a run at the witness or the other party to see. Maybe run your theory, maybe run your ideas and see how they play out. So that’s kind of one aspect. What’s anything else? Jackie?

Jackie Critzer 1:58
Well, I think too, you you’ve got so that you’ve got the parties, right, but it’s sworn testimony. So it’s under oath, you’re you’re sworn in, I swear to tell the truth. There’s no judge. There. There’s I mean, it’s just the attorneys in the in the person or people being deposed. And the point is to try to get as much information as you can to move the case forward towards trial. But part of that process means that if a person answers a certain way, in depositions, and in trial answers a totally different way, well, then you can use the depositions to impeach them or to show that they’re lying at trial. Or at least ask them to explain the difference in their answer to the exact same question. And that can be very helpful, of course, in succeeding and at least, impeaching that person’s testimony and discrediting them in front of a judge or a jury.

Scott Cardani 2:47
So, you know, just so we’re clear, the deposition is a non court event. Usually in an attorney’s office where you’re under oath with a court reporter, she like she said, she’ll swear, are you insane? Do you swear to tell the truth, the whole truth, nothing about the truth. And some people use So Help me God still. And some people don’t. But that’s the deal. And so we are there, your attorney who will be there? Let me ask that.

Jackie Critzer 3:15
Well with you, so your attorneys with you the other party, so the other litigant, so plaintiff and defendant with their attorneys, if there are any. And if the parties aren’t being deposed, if it’s not the plaintiff or the defendant, they can still be in the room because there are parties to the case. And let’s just say it’s a witness for one of the people they can come in. But aside from the parties and their attorneys and the court reporter there shouldn’t be anybody else in the room unless that person is being deposed.

Scott Cardani 3:45
And just to be clear, Jackie said the witness there may be a witness coming in to be deposed in that case. Like, say, Jackie’s uncle was the person who caught me doing something wrong in the divorce. So he’s going to testify, so he’s going to come in to depositions. Jackie, Jackie’s uncle will be in the deposition. Jackie, myself, and our two attorneys will be in the deposition.

Jackie Critzer 4:04
Exactly right.

Scott Cardani 4:06
That witness can’t just sit in there while I’m deposing Jackie. Because right? It like in a courtroom at a deposition is much like a operated much like a courtroom. And what I’m saying by that is we normally in a case where we have witnesses, we exclude the witnesses from the courtroom prior to trial, starting the trial. So one witness goes at a time. And the reason we do that is so that the witness’s testimony isn’t influenced by the other testimony, or they’re not given keys on what to say or something like that. So basically, it it keeps the testimony, honest, straightforward, and from their perspective. The idea is not to cloud it or color it somehow or to have some plan in cahoots.

Jackie Critzer 4:50
Right. Well, and I will say to you that in depositions, the rules are a little different, right than in court. So the rules of evidence that that you And when you’re watching TV, Objection, Objection, and whatever the objection is at the time, those don’t really apply to depositions. But for a very narrow exception, and why is that? Why don’t the rules of evidence apply in depositions?

Scott Cardani 5:13
Because it’s discovery. And it’s not a court. That’s the number one reason but the other reason is they actually apply, but you don’t have to litigate it. So it really kind of becomes a hinderance and what you can do is, I still object on the record. And then I can make that part of the transcript not be allowed to come in and things like that based on the judge. And sometimes you have to give the judge more during the depositions. Maybe somebody refuses to answer yes. And you have to make a phone call to the judge. Hey, we’re doing depositions day, Johnny was not going to answer this question judge can make a ruling right there, we go back on the record and do that. But that becomes really burdensome, sometimes it’s better to object and figure it out later. There’s just lots of strategies that you and your attorney / us will talk about.

Jackie Critzer 5:58
So let’s speaking of strategies, right, so what’s the what’s the purpose? I mean, we talked about potential impeachment during a trial. But why else? Are you really calling for depositions in a case?

Scott Cardani 6:10
I honestly think that’s probably there’s two to me that are primal. Number one is that kind of getting them to say something different than they may say at trial and tracking that, but the other one is to get more discovery. For instance, say I send out a questionnaire to Jackie and I said, in my written discoveries, which are called interrogatory ease, as all the word means question, just like you’d learned in grammar school, and rogatory is a question. So I have so many questions, I can ask her in written form, and she has to answer. So maybe she answered. I said, Where were you on October 31, at 1am in the morning, and she answers in Texas. So in depositions, I can go okay. Jackie, you answered that you were in Texas on October 31. Where were you in Texas? You know? And she goes, Well, I don’t know where you are to hotel, Jackie, you know, and I can start digging into where she was? Who were you with? Why were you there? You know, it may turn out to be completely innocent. She may say, Well, I was at a conference, what do you mean, you know, and sure I was with my daughter, she was in a hotel room, you know, it may turn out to be your benefit. But the idea is for us to dig a little deeper. Sometimes to find a little more discovery that we didn’t get those answers, or maybe even a question we didn’t ask, because maybe when we sent out discovery, let me say it this way, when sometimes when you send out discovery, you get answers that create more questions. Sure. Oh, that’s an even different question. So sometimes this this deposition is going to be like, Wow, I need to ask this question, I need to figure out why she answered this way. And so you’re just digging deeper, again, to try to resolve the case to try to prove your evidence in the case. And ultimately, a good deposition can sometimes lead to settlement.

Jackie Critzer 7:59
I think that’s that’s true, too. You know, sometimes, in request for production of documents, still part of discovery, you might get, you know, 12 months or 24 months of bank statements in any kind of case, right? It doesn’t have to be just divorce, it could be really any civil case. And, and you might see some deposits that are strange, you might see say, payroll deposits, and then you see these other maybe large cash deposits or large cash withdrawals. And you want to ask questions about that, because maybe that leads to the next piece of your case, whatever the case may be, but it is a way to expand whatever information you’ve already received. And it’s it’s really best used to dig a little deeper into discovery that’s already been issued, like we wouldn’t do depositions at the beginning of a case, you would do depositions, after no other forms of discovery, I think had been used.

Scott Cardani 8:51
I think that too. And I think one of the things I see most often is two things. There are sometimes people who are very unprepared and depositions. And I mean, lead counsel that attorneys, and it becomes really like, random, like it’s everywhere. That’s hard for both all parties. Honestly, it’s hard for you as the person being deposed to track what he’s talking about. It’s also hard for the attorneys to track where it’s going. And it just becomes really confusing sort of mess. But again, it can lead you to trip up and say something different than what you really meant because the way the questions are answered, so you have to really be careful when you’re answering questions. And I always tell people this slow down. If you have to repeat the question in your head you’re not in a race and what they people try to do even in even in courtrooms is. You try to get people going and get them going and get them answering questions and then you throw it on a softball question or a hardball question or a complete trick. And they may answer the way you want them to and so people fall for that but you always need to just be aware, this is not a big deal. I can handle this. And when they’re asking the questions, you can control the pace by slowing it down, say, okay, he asked me where it was on October 31. Let me answer that. Is there anytime you shouldn’t answer a question?

Jackie Critzer 8:51
When your attorney objects, you should maybe not answer the question, right? You just sit and wait, if the attorneys start talking over each other, which we do from time to time, stop talking, let the attorneys figure out what needs to happen next. And if you are then directed to provide an answer, and your attorney is in agreement, then provide the answer. But you definitely want to stop when your attorney steps in or, you know, if you’re unsure another time is if you’re unsure what the question really is asking. Sometimes, we attorneys don’t mean to be confusing. Sometimes we mean to be confusing. And so if you the person being deposed, don’t really understand the question being asked and don’t answer the question you think is being asked to clarification or most? Because important if the attorney is asking, I mean, how is it going to read another transcript? Right? The the attorneys asked the question, you think, you know, well, I’m trying to decipher Okay, I think I know what was being asked, and then you answer and then you go back and you read? Oh, that wasn’t the question you were asking. And now it looks like something totally different. You don’t want that you can, you can walk it back. But it’s far more difficult. It’s much better to just say, I’m not really sure what you’re asking me in that question. So that would be another time not to answer right away.

Scott Cardani 11:28
Absolutely. And you got to remember that, folks, it it’s just like on a test, sometimes all of us taken test, where we thought the professor or the teacher was asking us one thing. And we answered a certain way, because we made some assumptions. And what we’re trying to guard against is that really, you shouldn’t make any assumptions in a deposition, especially if you’re being deposed. Because it’s the attorneys job to make that question very crystal clear. So you answer a crystal clear question. And if he can’t do that, I actually was in a deposition one time where the poser will call them really was having trouble stringing together three sentences, and I’m not joking. And it was very, and I just kept telling my guy don’t you know, he kept looking at me sure I try to get no, don’t answer it, she needs to ask articulable question. And if they can’t do that, you don’t have to answer something that you’re guessing about. And that may take some time. But again, you have no pressure in this Don’t feel pressure, you’re already there. You know, it’s already a bad situation, from your perspective, because you don’t want to tell your story again, and sometimes stories are really rough to tell. So it makes it very difficult.

Jackie Critzer 12:32
Is there a time in a criminal case, Scott, that you might find depositions useful? And if so what sort of scenario might that be helpful?

Scott Cardani 12:41
I think for me, I’ve almost never used them in in criminal cases. And for lots of reasons. I don’t know that some guys use them. And I think sometimes we use them for for witnesses to get their story down. And make sure you have the story. So when they go to court, they don’t change that story, that might be a way to do that. But for the most part in criminal cases, I don’t think they’re effective or fruitful. And quite frankly, in most cases, people change the story all the time.

Jackie Critzer 13:12
And so I would, I would say, I mean, I do mostly civil work anyway. But I would say that Depositions are most useful in civil cases. And it’s with witnesses and with parties. I’ve used depositions also in bankruptcy litigation, not just now, I wouldn’t use it in a normal bankruptcy case. That’s a strange I wouldn’t that’s just weird. But in a bankruptcy litigation case, I have been able to use depositions and very effectively, so same same concept expanding on the Discovery that’s already been asked, sometimes you want to go over their answers in the pleadings, right? So I file a complaint against Scott’s client. And Scott’s client says, oh, yeah, well, here’s my answer, and also a cross complaint or a counterclaim against my client. And so it’s a way to dig into those answers as well. And to flesh out, you know, where did that come from? How did that happen? Which didn’t wouldn’t necessarily be uncovered in discovery, but or maybe it would be so it can be a useful tool, I would say most civil cases.

Scott Cardani 14:13
I want to ask some more questions, I think are important for people understand. Can you have somebody in the deposition with you? Like, say, a family member friend, because you’re nervous?

Jackie Critzer 14:26
For moral support?

Scott Cardani 14:26

Jackie Critzer 14:29
The answer is, it depends on it depends on whether the person is a witness in the case. If they’re a witness in the case, I’m sure the attorneys are gonna say no way that person can’t stay, no way.

Scott Cardani 14:39
If they’re a judge is gonna say the same thing.

Jackie Critzer 14:41
Completely. If they’re not a witness, then the answer is… And no chance that they will be – right who can predict that that’s, that’s the catch. Who can predict it, that person is never going to be a witness, especially if they’re there. They’re familiar with you. They’re familiar with the situation. Is there some potential that maybe they could be witness some somewhere down the line. And if I’m the attorney who’s being asked, can this person sit in here? Most of the time, I’m gonna say, no. No, you can influence that person might influence their answers. That person might one day become a witness. And we didn’t realize it at the time of depositions. But now No, no, most of the time, I think most lawyers are going to say, No, you can’t. You have your attorney, as your moral support. That’s who you get.

Scott Cardani 15:25
And, you know, you can have the situation and I know this happens quite often. Jackie’s here for my moral support. And I’m talking about my trip to Cancun and she, she has no idea at first and all sudden, she like flashes, like, you know, and I see is the other attorney, she knows something and all sudden, she’s a witness, because I may need to depose her now. So, you know, if they’re your good friend, they probably know more than you think they know. And those kinds of things. So they’re not that tough. I mean, normally, Depositions are pretty low key,. In the sense of, they’re not like a courtroom. They are pretty tough, but they’re not they are a little more low key. What about video? deposition, you know, everything since COVID. Everyone wants to do video depositions, and be away.

Jackie Critzer 16:09
So I actually participated in like zoom depositions. And I’ll tell you, I thought it was it was very difficult to really get a grip on the person I was deposing. Because the person I was deposing and the attorney were on two different cameras. And I will say that there were times where I asked the court reporter, to have the record reflect things that I thought were going on, that didn’t seem appropriate. But I wouldn’t voluntarily do that. That was definitely a COVID situation or near, you know, during the COVID time, and it was it made more sense for everybody’s safety at the time. But I wouldn’t voluntarily do that. Now. I mean, that that it’s, it’s just like trying to do court via video. It’s not that it’s impossible, but it is far better to be in person, read people’s body language, read people’s expressions, and see what’s really influencing their testimony and a face to face situation, it just makes a difference in in how you are able to ask the questions and perceive the answers.

Scott Cardani 17:09
You know, stress and all those things in a courtroom are very big indicators. Things we use as really good attorneys to decide how we’re going to go and where we’re going to go. Videos take away that stress take away that the observation of body cues, tics, hand movements, leg movements, you know, some people start tapping their leg, you know, if you’re on a video, you can’t see that. And sometimes in the courtroom, you can’t see that to be fair, but I’m rocking everybody. Sorry, folks, if I’m moving too much. But my point is this, you I can’t think of a time that I want to video over the real live thing for any reason. And there are things in the code that give you a right to video depositions, for instance, the person’s way out of town. You know, listen, another state, those kinds of things are reasons to do it. But I’m telling you right now, in our practice, and the number of years we’ve practiced, which you know, people practice a lot longer. And so we’re not like, but we have a good amount of practice under our belt. And now, when you’re starting to get to 30 years, you practice a lot and seen a lot. And, you know, I can’t tell you how many times I’ve been in a courtroom where the body language gave me the clue to where I needed to go next. And literally one the case for me because I was able to perceive that, that tension in a courtroom, all those things, make things come out, maybe that don’t normally come out. And you really do need that even in a deposition. I just think it’s so important to have every element and to be able to read everybody in the room. Like Jackie said, sometimes there’s some shenanigans going on and the attorneys trying to help the person to answer and things like that, which is not okay. So anyways…

Jackie Critzer 18:44
And no, and that’s, you know, what you bring you bring up a really good point. No, your attorney cannot help you answer questions. No, under any circumstance, no, not in a deposition. interrogatory is request for production of documents, they can’t answer the question for you. They can help you with language to get the answer out, that needs to be out. But they can’t like in a deposition, they can’t write you a note and tell you what to say. In TV, you often see the attorney, you know, say, hey, if I if I stomp on your foot, don’t answer the question or say you need to go to the bathroom. And really, that’s not even really appropriate. It does happen. But they but an attorney cannot help you answer questions in a deposition any more than they can help you answer a question in court.

Scott Cardani 19:25
That’s very important. And that leads to our final point with his truth. I can’t think for me, one of the biggest things I’ve ever seen in depositions was the idea that somebody was trying to catch somebody in a lie to use it in court later to say that you lied about. And I’ll give you a prime example of something simple that people don’t do. I once had a criminal case. And the guy was in depositions, because of a certain segment situation we and he was doing lie detectors and that was on being videoed and one of the first things that I asked him was have you ever told a lie? And he said no. I mean, what I mean, it’s ridiculous because he thought he was under oath and he thought he had to, you know, say everything was truth. Or they, they asked a stupid questions like, Have you ever smoked marijuana when you know? And you know you have or you haven’t? It doesn’t matter if you haven’t I’m just saying Be truthful. If that doesn’t, the answer to that question doesn’t matter. And so what they’re trying to do is get you to lie. I’ll give you one more example, I had a lady in a really bad traffic exit case, one time, who had some marital counseling at one time, way long time ago. And it was embarrassing to her. And when she was asked about doctors and counselors, she didn’t tell didn’t say anything about it. And so later, the other guy goes, Hey, she lied. This is the record. She was clearly counseling for six months with this and this guy, because they can get things and records. And so it’s just not worth it. If you’re worried about a question. That’s our job. We’re good at it. I would I’d rather much rather you just tell you tell the truth. Now, I’ll say this. This is super important too. Just because somebody asks you a question doesn’t give them the right to the answer. And so truth is when you have to answer answer truth, answer succinctly don’t go off and try to justify or explain it, that’s even worse. So you know, maybe, for instance, I realized marijuana is now somewhat legal when all those things, but it’s a good example, like, especially from years ago, like somebody say, Jackie, have you ever smoked marijuana? Well, once and I was really sick. And, you know, my mom had just passed, and it just sounds like you’re lying through your teeth at that moment. Right, you’re trying to justify so, you know, trying to think of a good.

Jackie Critzer 21:48
Well, and you know, what’s funny, though, is will do those answers matter if you lie about something like smoking marijuana, or you lie about, you know, something that’s not really directly related to the case doesn’t matter. And absolutely, absolutely, it matters. They can show that you’ve lied about something, they can cast doubt about all the things that you’re testifying about, which is just about the worst situation you can be in if you’re getting ready to go to trial.

Scott Cardani 22:15
That’s what impeachment means. And as that idea that if I can show that you’re lying about one answer, that impeach is your testimony, which makes it less credible. And it follows that whole thread and it’s like, I don’t want that.

Jackie Critzer 22:27
Well, right now. Right now. They’re, they’re they’re airing part of this trial, about some person who does like a video blog, or I’m not sure if his name, so I won’t even say it. But he’s on trial right now for, I believe, defamation of the mass shooting a sandy hook. And you’re watching The judge. And the judge says to this person, you lied about this today, you lied about this today, sir, you are in this courtroom, and you’ve been sworn to tell the truth, and you’re not telling the truth. And I just I mean, you just don’t understand the implications that that’s going to have for him, no matter what he says, and this is in front of the jury. She’s telling him, I think I think the jury was still in the courtroom when she said, I’ve already seen you lie about these two things. Maybe the jury wasn’t in there. Don’t Don’t quote me on that. But it’s it makes a difference in and of course, if a jury if it’s a car accident, okay, and you’re talking about injuries, and you they’re able to catch you in some sort of untruth, some sort of lie, or at least lead the jury to believe that you’ve been untruthful about something the jury may have a hard time believing in you know, and that you were really injured, for example, which is going to have an impact on how much money is awarded?

Scott Cardani 23:41
Yeah, it’s just like this thing. There’s something inside of sometimes when we’re embarrassed about a situation, or we’re not proud of it, that we don’t feel like we need to share that and I get it, trust me, I do get that. But in a deposition, remember, there’s only five people in a room, six people in the room, right? The other attorney does this every day, he doesn’t have time to go put it on his blog. This lady was in here today and said this and this and this. So it’s not gonna happen. I mean, that whole idea that you’re going to be shamed and put out to pasture and all these kinds of things is, is not a reality. And it’s really important that you understand that. So in a deposition, just be truthful. be succinct in your truthfulness. Did you smoke marijuana? Yes.

Jackie Critzer 24:21
And if your attorney will have the opportunity for a follow up question, how old are you? When was it? How many times if it Matt, I mean, if it matters, right? You know, I tell people a lot that if a judge has a question or in a bankruptcy if a trustee has a question, and they say Oh, I like your shirt, where did you get it? Right? This is a question no judge, no trustee is likely to ever ask unless maybe it’s pure gold or something silly, but they’re not going to ask it which is why I use it as an example. Where do you get your shirt? I like it. Well, I first went to Kohl’s and then I went to Target actually ended up though at Dillards. And that’s where I got it. No, no, no, the answer is I got it at Dillards.

Scott Cardani 24:59
You know Yeah, there’s two kinds of people in the world, I think one more than two. But I mean, what we experienced a lot is that people will want to tell the whole story like that, like she was saying, and then the other people want to be so succinct, almost to be look like. Did you have a gun? Sir? Well, I’m not really? And the answer is yes, they had a gun. You know. So my point is just answer the question. Just say yes. And did you have a gun? Yes. Let me or the other attorney asked another question. Did you have back surgery when you were 20 years old? Yes. I mean, there’s not It’s not tricky. It’s not tricky. And it seems like it is, it seems like they’re trying to lessen your case. Don’t. Don’t worry about that. Just be truthful. And if you think something’s gonna come up in that deposition, that you’re not excited about talking about talk to your attorney versus a Hey, make sure they know for sure. I’ll tell you the other thing. And I’ll close, we’ll close with this. But you know, prepping for a deposition can go two different ways in life. And I feel always feel like I don’t want to over prep people. If it’s truth is the truth, just tell the truth. And I don’t want to get in that because then you look like you’re trying to answer questions, because I told you what the answer and then you look like a liar again, looks like it’s not the truth. Like if you prepare your statements with he has this I’m gonna say XY and Z. And then you’re trying to remember, Okay, I gotta answer it this way. I went to the doctor in January, but I didn’t do this. And I did do it. And then you just get confused. It’s just so much easier to just answer the questions, especially in depositions, right? I think that’s a big mistake a lot of attorneys make because they over prep their witnesses. The witnesses start to feel like they’re scripted, and they’re not real, then you don’t come off authentic to the jury, that judge or anybody else. And again, that comes to that whole impeachment idea. When you don’t sound authentic, when you don’t sound truthful, when you don’t sound real. It kills you. So just remember that we’re here to help. You know, Depositions are scary, don’t go into depositions alone. I often even think sometimes if you’re being deposed as a witness, you may want to talk to a lawyer before you go into that deposition about what your liability could be, you know, sometimes, especially in civil matters, all sudden, you get a charge against you because you went a deposition. And that, you know, said something you shouldn’t have said, so. So, Jackie, what are our takeaways from today?

Jackie Critzer 27:22
Well, the first takeaway is what are depositions, what, what are they used for, and keeping that in the back of your mind as you prepare for them.

Scott Cardani 27:29
And the second one is why you’re doing depositions again, it’s discovery. It’s a form of discovery to get more information.

Jackie Critzer 27:36
And finally, the truth whether you’re a witness or you’re a party, if you’re the person being deposed, it’s important that you are truthful about all of the things you’re being asked about, not just the what you think is relevant to the case. But all matters be truthful in all matters.

Scott Cardani 27:52
Alright, guys, thanks for listening. We did we have promised that we’re going to do some of these cases that have recently come down from the Supreme Court. They’re obviously big, we’ve gone through them, we are getting prepared to do some podcasts on those. They’re very important decisions. A lot of people are misunderstanding the decisions and what they really mean.

Jackie Critzer 28:10
And misrepresenting them.

Scott Cardani 28:11
And misrepresenting them, it’s a big deal. So we plan on putting them out there and giving you our spin on them the best we can not spin actually the truth we believe they are saying. So we look forward to talking to you soon about those.

Jackie Critzer 28:23
Tune in wherever you listen to podcasts and be watching for the mini series on the changes in the law.

Scott Cardani 28:29
Like and Subscribe, subscribe. Thank you. Thank you. Bye bye.

What To Do When… Outro 28:34
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