Week 2 2020

To Ask or Not to Ask, That is the Question-in Depos

To Ask or Not to Ask, That is the Question-in Depos

The second week came, and the second week went in what seemed to be an instant. Another week replete with Summer Associate activities and work assignments—just what the doctor ordered to cure the stay-at-home blues.

Depo Workshop!

This week began with a seminar hosted by Orlando partner Darryl Gavin in which my fellow Summer Associates and I were instructed on how to prepare for and conduct a deposition. The seminar we attended was in preparation for a workshop hosted on Thursday of the same week in which we were to conduct a mock deposition of the plaintiff in a case where he sued his home insurance company (my client) for breach of contract.

Despite having been prepared for this deposition by a partner, who has [by his count] successfully deposed over 2,000 witnesses in his career, developing questions, combing through the case file, and strategizing how and when to ask questions was very difficult especially in a virtual setting. But I was excited. I know that I am lucky to have this excellent opportunity to hone such a fundamental skill in a law firm setting.

Truly, deposition taking is an art, and law school does not adequately prepare you to take a one. It’s not like the movies, but in some ways, it’s better. It was wholly satisfying to connect with the plaintiff (played by Darryl and represented by Tampa associate Robert Barton).  However, during my introductory statements and questions “Mr. Gavin” was not an easy witness to depose or get information from, nor was Mr. Barton an easy opposing counsel. But that’s what made the experience worthwhile. Darryl made me fight for every nugget of information, and, to the best of my ability, I fought.

While I did not meet some of the objectives I set for myself before heading into the deposition, I was very thankful for the experience and especially for the feedback I received afterwards. Miami Administrative Partner Scott Sarason joined the virtual deposition and recalled his first deposition experience as he discussed my performance in the mock deposition. After taking thousands of depositions throughout his career, Scott still remembers his first. I expect I will too. Without a doubt, I will apply that feedback on my very next deposition and every one thereafter.

This week was not all deposition prep, however, as I was lucky enough to go to lunch with partner Suzanne Singer and associates Magali Sanders and David Acosta, all three of which are fellow Florida International University Panthers!

It’s always great to get to know people on a more personal level over lunch. We had an absolute blast. Following that lunch, I began working on a draft of a response in opposition to opposing counsel’s motion for Suzanne in a negligence case, and I’m very excited to see the finished product. This is yet another incredible opportunity to do substantive and important work, and I couldn’t be happier that a very skilled partner will guide me through my first response in opposition.

Just as my first week, my second week ended with lunch with partner Josh Learner. As a fellow Law ‘Cane and lifetime Miamian, Josh and I clicked instantly. As the summer program continues, I look forward to cultivating a mentor-mentee relationship with him.

At the end of last week, I was eager to see what this week and every other week would bring. I am happy to report that week two was even better than the last! Here’s to more! Next stop? The 2020 RumbergerKirk Writing Competition!