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Deposing a pro se litigant tomorrow: should I object to nonresponsive answers?
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Date: April 25th, 2018 9:37 PM Author: Maroon karate sandwich This guy is a tard who will flat out refuse to answer questions. I already had to file a motion to compel because he refused to answer interrogatories and admissions, and will almost certainly have to do the same when when I depose him. If he responds with some bullshit spiel about some unrelated topic do I object to the answer as nonresponsive and ask the court reporter to certify the question and response so I can use it in my MTC? Never had to deal with this bullshit before since every deponent I've ever dealt with has had competent representation. (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921180) |
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Date: April 25th, 2018 9:40 PM Author: Deep Gay Pistol if you sense the pro se PLaintiff will not cooperate, you might first advised the Plaintiff that we will have no choice but to seek court intervention. This scares some pro se's and gets them to see the light. But, if that doesn't work, just certify the questions as clearly as possible. you will appreciate the work up front as you begin drafting your motion to compel the testimony. (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921198) |
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Date: April 25th, 2018 9:52 PM Author: Maroon karate sandwich Is there any point in objecting to the answer except to unnerve him?
I've already advised him many times of the consequences for failing to answer and judge has granted my MTC on written discovery, though his deadline hasn't lapsed yet. |
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Date: April 25th, 2018 9:55 PM Author: Yapping Gas Station Generalized Bond I had never even heard the term "certify the question" until your post. (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921272) |
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Date: April 25th, 2018 11:20 PM Author: boyish sable ladyboy hospital cr. is this some shitlaw flame? (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921929) |
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Date: April 26th, 2018 10:39 AM Author: Yapping Gas Station Generalized Bond Some half-assed googling suggests it is a regional thing rooted in older versions of rules. (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35923854) |
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Date: April 26th, 2018 1:13 PM Author: boyish sable ladyboy hospital sounds like something retarded like 'the usual stipulations' (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35924746) |
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Date: April 25th, 2018 11:34 PM Author: Bossy electric new version friendly grandma (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35922006) |
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Date: April 25th, 2018 11:41 PM Author: Dashing insecure potus state he means just read back the question and answer so he can have a clean copy of it for some motion or whatever he's going to do. (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35922052) |
Date: April 25th, 2018 9:45 PM Author: Talking Racy Philosopher-king Dysfunction Tell judges secretary you have pro se deponent tomorrow (so judge will be sure to dodge your call to chambers when he's fucking around w answers.) (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921223) |
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Date: April 25th, 2018 9:51 PM Author: Chrome whorehouse candlestick maker Depends. If you ask him substantive questions and he refuses to answer, or goes on some irrelevant tangent, you can use that in an MSJ. "Plaintiff was asked to specifically list all instances of [whatever] and was unable to identify a single concrete example. " (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921254) |
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Date: April 25th, 2018 9:53 PM Author: Maroon karate sandwich This is more of a "plaintiff doesn't want to admit he did some bad shit" kind of thing. (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921264) |
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Date: April 25th, 2018 10:01 PM Author: Aquamarine Main People Persian I would just focus on confirming testimony. If the issue is why he went to McDonald's, you ask "Why did you go to McDonald's?" And if he says "for a sandwich," you just drill down and always ask "Are there any other reasons?" Confirm he has nothing. If he is combative remind him non-responsiveness is not a grounds not to answer. Don't be afraid to call the court if he is a true dickhead. The threat may keep him in line. And most important, if he refuses to answer anything other than on privilege grounds LEAVE THE DEPOSITION OPEN. When you are winding down just say we are done today but I am leaving this deposition open in light of your refusal to answer questions on relevance grounds. (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921319) |
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Date: April 25th, 2018 11:18 PM Author: Maroon karate sandwich ty (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921914) |
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Date: April 25th, 2018 11:35 PM Author: Maniacal jet-lagged spot filthpig (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35922011) |
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Date: April 27th, 2018 5:11 AM Author: Razzmatazz green locale (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35929828) |
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Date: April 25th, 2018 11:31 PM Author: Wonderful soggy alpha partner Ask him lots of questions about his citizenship status (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921991) |
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Date: April 26th, 2018 1:17 PM Author: Learning disabled appetizing wrinkle So what kind of case did this asshole file? (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35924757) |
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Date: April 26th, 2018 1:18 PM Author: Maroon karate sandwich The essential elements of the claim are "das racis" (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35924765) |
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Date: April 26th, 2018 3:09 PM Author: Maroon karate sandwich (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35925844) |
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Date: April 27th, 2018 4:56 AM Author: Yapping Gas Station Generalized Bond (http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35929801) |