I love depositions. I've done enough that they are no longer utterly terrifying but I haven't done so many that they are boring or ordinary. In the one and a half years that I worked at my previous firm, I'd taken 11 depositions. For a baby lawyer, that's a pretty good start but, for anyone else, it's not really that impressive.
I have an unbeatable first deposition story. The day of my first deposition, I was a nervous wreck. I had prepared a 7 page outline for a simple plaintiff deposition. I packed extra outlines, extra copies of every single medical known record, extra pens, and extra business cards. I googled the directions to the plaintiff attorney's firm, arrived 20 minutes early, and took a brisk walk/nervous pace outside the office until show time.
When I walked into the office, which was almost in the middle of nowhere, I was sweating like crazy behind my thin, grey Banana Republic suit. The receptionist led me down a winding corrider until we finally arrived at a small conference room. I walked into the conference room and saw this:
I took the entire deposition just one foot away from this:
In fact, I think his outstreched claws were just inches from the back of my head. Good thing I wasn't inclined to make any sudden movements.
During the middle of the deposition, and right in front of his client, the plaintiff's attorney went on a tirade about how his horrible ex-wife had left him, had stolen his home, and was poisioning his children against him. Sadly, and for some off reason, none of this made it into the official record....After the deposition, the opposing attorney wanted to show me something in his office. I was a little worried and had decided not to actually enter his office alone when I heard a high-pitched "yap" coming from under his desk. He was hoarding a golden lab puppy. Under his desk. What?!
Today's depositions weren't quite as exciting. But they were my first deps in over a year so I was a little (ok, a lot) nervous. As I was driving down a wooded highway toward the destination of the deps, I started to rehearse my questions. All of a sudden, I noticed a cop behind my with his sirens flashing. Crap! I looked at my dash and noticed that I was speeding. I was speeding a lot.
When it comes to being pulled over, I'm quite seasoned. I had gotten so many "warnings" that I was beginning to think that traffic cops in my county were a joke. "I'll probably just get a warning," I thought. I'm cleaned up, wearing a suit, and I look business. When the officer took my papers back to his car and spend the next 7 minutes working on his fancy computer, I knew I wasn't going to be so lucky. $124 later.....
I didn't mind the ticket, I mean, I DID deserve it. But the whole ordeal threw me off and made me even MORE nervous. It also made me late.
The first deposition was rough. I was still obviously flustered and out of practice. On record, I called the deponent by her first name instead of Mrs. ____. I felt really badly about that but when I tried to correct myself, I had forgotten her last name. Not a good start. And my questions didn't come out as smoothly as I had practiced. How come I can give a flawless performance in front of the mirror at home just to flop wildly like a dying fish at the real thing?
My final line of questioning for the first deponent was the important one. Thankfully, I think I nailed it. Then we took a short break before I started deposing the second person. The second dep went pretty well until one point when I asked about an event that had happened long ago. The guy studied me then said sharply, "I can't remember. Frankly, I doubt you were even ALIVE then." Now, overall, this deponent was a very nice guy. He probably hadn't meant his comment to be rude. But the comment made me very mad. It was unprofessional. I know I look young but when I show up to do the job of a lawyer, I expect to be treated like one. Comments about my appearance or age undermine my purpose and suggest that I am not qualified to do my job. That, I take seriously. Fortunately I was able to keep my cool, force a smile, and press on with my questioning. Deep down, however, I felt deflated, angry, and full of self doubt.
At the end of the day, I was glad to have more experiences under my belt. Still, I can't wait for the day when I feel confident enough to not let people shake me down so easily. Being a baby lawyer is exciting but it also sucks in many ways.
When I came home, I got some much needed quality time with my three men. Jacob and I did some puzzles. We took turns trying to make Ryan laugh. I managed to squeeze in a 5 month photo shoot of Ryan for his baby book. Then I tucked my sweet 4 year old into bed, rocked my angel baby to sleep, and watched a feel-good movie with my husband. Ahhh, all in a day's work.
P.S. Last night, when I was trying on my suit for today (thank goodness for a long suit jacket to cover the top of my skirt that I wasn't able to zip all the way- damn you baby fat!), Ryan and I had a little fashion show:
"Mommy, can I come to your deposition? I'll wear my best tie!"