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More things I wish I knew when I started
Attorneys lie!!!!
When they say, oh, I've only got an hour, can we work through lunch? He's lying!!!!! They will go on for hours while you're passing out from hunger. If he is saying this at 12. Smile and say no problem, but let's take a five-minute restroom break or something and grab the energy bar out of your bag or run to the nearest vending machine to get a little something to eat.
Attorneys do not like for you to ask them how long the deposition will be. If you must do something at 3 o'clock that day, I suggest you do not take a depo and work on transcripts at home. Bec. if you do take that depo, that depo will go to 7 o'clock at night. I don't care if the agency says the attorney has an airline flight at 2 p.m. Attorneys can and will change their flights at a moment's notice. This happened to me just this Friday.
If you do take the depo, do not ask how long the depo will be in front of opposing counsel. Sometimes attorneys want the other side to think they are willing to stay until the wee hours of the night. It's part of their "strategy". It would be better to ask the attorney on a break, preferably outside the presence of counsel and the deponent.
When attorneys give their admonitions at the beginning of their depositions, they often say the reporter is the most important person in the room, let's not interrupt her, it makes her job more difficult. More often than not, they will spend the next ten hours(slight exaggeration) proving they did not mean a thing they just said by continuously speaking over the witness, you, opposing counsel and refusing to take meal breaks.
When they say they want it expedited and they say asap. You turn it in the next day, and they say, oh, I don't want to pay for an overnight, it would have been fine next week, always pin them down on when. Asap tomorrow? Asap Wednesday? Always try to pin them down at the time they make the request. Set the expectation. This way no one will be disappointed.
Here is my response to the attorney when he asks how soon can he get it. This question is usually the lead up to the ever popular how much will it be and the request for an expedite. Bear in mind that the standard turnaround is 10 business days. When the attorney asks me how soon can he get it. I always ask as soon as you want it, but there will be a charge. When they ask how much, refer them to the agency. Trust me. You have no idea what the agency is charging them. Don't even try to quote them a price.
Get their order on the record. Or if after you've closed down the file, they ask for a rough and expedite and all that fun stuff, have them sign something or better yet e-mail just verifying their request for the above-mentioned items. AKA CYA. You really don't want to spend all night doing an expedite and not get paid bec. of a "miscommunication."
Any questions on attorneys lie?
When they say, oh, I've only got an hour, can we work through lunch? He's lying!!!!! They will go on for hours while you're passing out from hunger. If he is saying this at 12. Smile and say no problem, but let's take a five-minute restroom break or something and grab the energy bar out of your bag or run to the nearest vending machine to get a little something to eat.
Attorneys do not like for you to ask them how long the deposition will be. If you must do something at 3 o'clock that day, I suggest you do not take a depo and work on transcripts at home. Bec. if you do take that depo, that depo will go to 7 o'clock at night. I don't care if the agency says the attorney has an airline flight at 2 p.m. Attorneys can and will change their flights at a moment's notice. This happened to me just this Friday.
If you do take the depo, do not ask how long the depo will be in front of opposing counsel. Sometimes attorneys want the other side to think they are willing to stay until the wee hours of the night. It's part of their "strategy". It would be better to ask the attorney on a break, preferably outside the presence of counsel and the deponent.
When attorneys give their admonitions at the beginning of their depositions, they often say the reporter is the most important person in the room, let's not interrupt her, it makes her job more difficult. More often than not, they will spend the next ten hours(slight exaggeration) proving they did not mean a thing they just said by continuously speaking over the witness, you, opposing counsel and refusing to take meal breaks.
When they say they want it expedited and they say asap. You turn it in the next day, and they say, oh, I don't want to pay for an overnight, it would have been fine next week, always pin them down on when. Asap tomorrow? Asap Wednesday? Always try to pin them down at the time they make the request. Set the expectation. This way no one will be disappointed.
Here is my response to the attorney when he asks how soon can he get it. This question is usually the lead up to the ever popular how much will it be and the request for an expedite. Bear in mind that the standard turnaround is 10 business days. When the attorney asks me how soon can he get it. I always ask as soon as you want it, but there will be a charge. When they ask how much, refer them to the agency. Trust me. You have no idea what the agency is charging them. Don't even try to quote them a price.
Get their order on the record. Or if after you've closed down the file, they ask for a rough and expedite and all that fun stuff, have them sign something or better yet e-mail just verifying their request for the above-mentioned items. AKA CYA. You really don't want to spend all night doing an expedite and not get paid bec. of a "miscommunication."
Any questions on attorneys lie?
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Comment by Elizabeth A. Willis-Lewis on May 1, 2008 at 10:22
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This is excellent advice. I always have a granola bar in my purse for the occasions where the attys forget you are not a robot and continue on and on. I usually say, "I can go to 2 o'clock, but anything past that I will need a lunch break." When I first began reporting I would sit and listen to my stomach growl and deal with the headaches, but now........no way!
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Comment by Brenda Rogers on March 17, 2008 at 17:28
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follow-up with email is a wonderful idea, especially when you get a telephone order. I had one . . . *pause for nice word* . . . atty who ordered a transcript over the phone. I told her that it hadn't been produced yet, so does she still want to order the transcript? It wouldn't be a copy. Yes. Then she refused to pay the full price, saying that she understood it to be a copy. I *know* I explained the idea that she would be ordering the original, but she denies it. This was done by a subcontractor for me, so I refused to lower the price to below HER cut.
If I'd have followed up with a letter or email (I think this was before I came around to the realization that the Internet wasn't an evil thing waiting to infect my computer), I would have had something to fall back on. I will never do anything for that atty without something in writing.
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