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Did you introduce yourself?

Did you relax the witness

Do you wear glasses?

Are you taking any medications that would affect your agbility to recall or relate you r responses.

does court reporter automatically record day, time, etc. information

Are you able to give you best testimony

are you taking any medication that may hinder your testimony today

Yes, the court reporter's transcript will include the date and time of deposition

did you id your client?

do you ask them if they reviewed any documents to prepare for the depo, so you can ask them for them later

What to do if the PMK says to EVERYTHING, "I don't recall" or "I am not sure"

Rosab's questions is good: Ask if they reviewed any documents in anticipation or preparation for the depo; did they talk to anyone in preparation for the depo; and where they told what to say or given any information in ancipation for the deposition. If so, ask for the documents and information.

Yes, good idea to ask them if they reviewed any documents before the deposition

question was too vague

just ask the witness what her duties are

Let me restate the question.

If the PMK does not know the answers to questions that were listened in your deposition notice, you can demand that the other side produce a different witness who does know.

Could have asked if she does x, or does y?

You could redirect/restate the question if it was too vague.

Asked her to stop making the speaking objection. Narrow the question.

Say, you can answer if you understood

not a proper objection

could have narrowed the question or say you can answer if you understand

just say if witness understood the question they should answer

she was making improper speaking objections

Sue is though!

"deal with creepy boss"

Creepy boss?

the "creepy boss"

boss

the creepy boss

are you also looking to impeach the witness based on interrogatories, written discovery, previous answer to question earlier in deposition, etc.?

re impeachment - yes this can be valuable if the witness contradicts the written discovery.

In this LL-T example, how do you determine whether a depo is financially worth it? (For example, if the T loses, and there’s an attorney-fees clause in the lease, the T may be liable for said depo).

the litigant has to make that personal decision

It depends on how factually intensive the case is. Sometimes the facts are basically uncontested, and you don't need a depo because your whole defense is procedural

but, if your defense is based on oral discriminatory statements, or harassment, or other factual issues that are hard to prove through documentary evidence, a depo will be key

but for business records how do I establish that it's taken in the normal course of business etc?

don't I need some testimony to establish that?

I am not sure.

What would prompt the creation of the entry into the log?• How do managers direct the repair log?• Does a specific entry relate to this particular T?• Was request by T performed?• How long have you worked with the mgmt company?

What if a staff at the property management forgets to log a tenant’s request for a repair?

• When was the log prepared? What time frame does this log cover?• How often do you maintain the repair log?• Can people make edits?• Have you gone back and made edits to the log after the fact? If so, what edits? On what dates?• Who are the “other managers”?• Who are the maintenance and repair workers?• How is this maintenance log prepared?

b. How soon after you get the request does it go into the log?When do you update the log after the maintaince has been preformed?d. Who has access to the document?

How quickly after receiving a request do you enter it into the log?Do you recall receiving a request for repairs from plaintiff?Do you recall putting a request from the plaintiff in the log?Did you do this personally or did another manager?

Is it required by law? Does it comply? How many people enter/write it?

ow many people edit?

How do you maintain and prepare log? How frequently do you update it?

Is it complete?

who else touches/edits

How soon after getting a repair request from a tenant does the manager put it in the log?

Is it scheduled? Does it follow the schedule accurately?

Who has access to the document?

ORiginal? Copy?

Is it not a statement by a party opponent?

Time frame log covers?

How long has the log been used by the office?

Did anyone else prepare/edit this document? Doea anyone else have access? How is it stored? Exactly what date was the document prepared? Read contents into the record? Is this an accurate record?

how frequently are new logs started?

Any gaps?

is this the log from time tenant lived in building?

Was this log made in the standard course of business?

Log for each bldg?

Who else has authority to add requests to or maintain the log?Who decides which requests receive maintenance attention?Is the document a true and accurate copy?Where the entries added to the log at the time the requests were received?Are there procedures by which requests would not be recorded on the log?Are there procedures by which entries would be removed from log?By what means are requests included on log received?

what type of maintenance?

How are the logs prepared?

Anyone responsible for reviewing? Is it always same person?

types of maintenance logged?

Confirm date/accuracy?

can you only leave it open if you have not used the 7 hours total?

Hi Matt! Hope you are doing well, Moira

Hi! Thanks so much, this was great!

Can landlord question the history of the tenant about their behavior history to claim to evict them?

what is the program to get refund for depo transcript

Can you tell us what the contact info is?

"Transcript Reimbursement Fund"

thank you!

https://www.courtreportersboard.ca.gov/formspubs/trf_legreport.pdf

Thanks you!

https://www.courtreportersboard.ca.gov/licensees/what_is_trf.pdf

https://www.courtreportersboard.ca.gov/licensees/guidelines.pdf

is there a way to send out a copy of this chat? I am having difficulty cutting and pasting from it

what time is July 21 training?

thank you WCLP folks!!!Please do this again soon!!!! :-)

thank you. this was very informative.

Thanks so much! Great training!

Thank you all!!

Thank you!

Thank you!

Thank you!

thank you!

thank you! great training!

Thank you!

Thank you!!

Thankyou! Great training!

Wonderful training

Thank you!

Many thanks!