Example of Good Lawyering at Deposition

I won’t give specific comments publicly because I don’t want to tip off the opposition to why this was done so well and how he elicited the testimony he wanted. And while many of us who are veteran litigators could point to possible other maneuvers, we are talking style more than substance. This is about as close as you are going to get to perfection in the questioning the witness from your opposition. But I will say that this lawyer was extremely deft at posing questions designed to elicit the answers that show a witness is simply a paid patsy instead of a custodian of records or a person with any personal knowledge of the subject of a verification, testimony or affidavit.

Original Deposition Transcript of Angela Edwards (Carter 11-22504)

If anyone wants us to sponsor a seminar on techniques, strategies and tactics in examination of the witness for the banks and servicers, we would be happy to accommodate you and I would invite this lawyer to speak at that seminar.

The lawyer’s name is Evan Rosen, Esq., 2028 Harrison Street, Suite 204, Hollywood, Florida 33020 Tel: 754-400-5150. I don’t know him yet but I hope to get to know him soon.

And here is the transcript of a video deposition conducted in Jacksonville very recently. It gives me great pleasure to see talented, serious litigators like this entering the field after receiving the brush off from 100% of all lawyers I contacted in 2007 and 2008 and part of 2009. If I were a banker, I would be nervous.

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