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Deposing a pro se litigant tomorrow: should I object to nonresponsive answers?

This guy is a tard who will flat out refuse to answer questi...
swashbuckling flickering mad cow disease
  04/25/18
if you sense the pro se PLaintiff will not cooperate, you mi...
Erotic Corner
  04/25/18
Is there any point in objecting to the answer except to unne...
swashbuckling flickering mad cow disease
  04/25/18
I had never even heard the term "certify the question&q...
self-centered outnumbered gas station
  04/25/18
cr. is this some shitlaw flame?
Vigorous godawful gaming laptop famous landscape painting
  04/25/18
Some half-assed googling suggests it is a regional thing roo...
self-centered outnumbered gas station
  04/26/18
sounds like something retarded like 'the usual stipulations'
Vigorous godawful gaming laptop famous landscape painting
  04/26/18
...
canary deer antler
  04/25/18
he means just read back the question and answer so he can ha...
diverse field legend
  04/25/18
Tell judges secretary you have pro se deponent tomorrow (so ...
Cream dashing box office dog poop
  04/25/18
Depends. If you ask him substantive questions and he refuses...
Garnet buck-toothed idea he suggested quadroon
  04/25/18
This is more of a "plaintiff doesn't want to admit he d...
swashbuckling flickering mad cow disease
  04/25/18
I would just focus on confirming testimony. If the issue is ...
swollen bossy forum
  04/25/18
ty
swashbuckling flickering mad cow disease
  04/25/18
...
insecure dead rigor
  04/25/18
...
Big-titted Bateful Digit Ratio Library
  04/27/18
Ask him lots of questions about his citizenship status
Titillating french becky sandwich
  04/25/18
So what kind of case did this asshole file?
Fluffy sepia theatre kitty
  04/26/18
The essential elements of the claim are "das racis"...
swashbuckling flickering mad cow disease
  04/26/18
...
swashbuckling flickering mad cow disease
  04/26/18
...
self-centered outnumbered gas station
  04/27/18


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Date: April 25th, 2018 9:37 PM
Author: swashbuckling flickering mad cow disease

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: Erotic Corner

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: swashbuckling flickering mad cow disease

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.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921256)



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Date: April 25th, 2018 9:55 PM
Author: self-centered outnumbered gas station

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: Vigorous godawful gaming laptop famous landscape painting

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: self-centered outnumbered gas station

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: Vigorous godawful gaming laptop famous landscape painting

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: canary deer antler



(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: diverse field legend

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)



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Date: April 25th, 2018 9:45 PM
Author: Cream dashing box office dog poop

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: Garnet buck-toothed idea he suggested quadroon

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: swashbuckling flickering mad cow disease

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: swollen bossy forum

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: swashbuckling flickering mad cow disease

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: insecure dead rigor



(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: Big-titted Bateful Digit Ratio Library



(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: Titillating french becky sandwich

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: Fluffy sepia theatre kitty

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: swashbuckling flickering mad cow disease

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: swashbuckling flickering mad cow disease



(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: self-centered outnumbered gas station



(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35929801)