"The Velvet Hammer" Blog — Karen Koehler

If at first you don't succeed... moving to stop improper deposition objections

Ms. A (she of the 257 objections ) is defending another deposition. This time of an electrical expert. Her stream of objections has not changed course since Mr. T's deposition.

I challenge her on the record. This is to satisfy CR 26i should I decide to bring a motion:

K3: What's wrong with the form? I think you're being abusive with the objections.

A: You're not setting a foundation, you're just saying -- you're making conclusory statements and then asking him about it. He has nothing to say that --

Karen KoehlerAugust 21, 2015deposition

Is it improper to object 257 times in a deposition.

The Tale of Mr. T has one more chapter. Following part 2 of his deposition, I am on a seminar panel for AAJ in Montreal along with Federal Judge Bennett. He is talking about his now famous order sanctioning a national defense firm for deposition abuse. His speech is exceptional. He urges us to not be content with the minimum bar set by court rules . To strive for a higher ethical standard. He is inspirational on so many levels.

Karen KoehlerAugust 19, 2015deposition, objections

Nala goes kayaking

Oh goodie. Oh goodie. Yay. Yippee.

We are up here at the cabin. Am looking out the window in the living room. Watching her carry the little blue kayak down the hill. She is trying to mimic Sol who balances the big kayaks on top of his head. Oops. There it goes over to the left. She hefts it up. Then it slops over again. She looks like a wobbly blue turtle as she makes her way down.

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