Hello,

I took my first depo last week and was asked to mark a motion. I'm totally clueless and not sure what that means. Can anyone please help me? I was thinking it was possibly doing a certified question page and adding it to that, but I'm not sure if that's right.

Anything helps. Thank you :)

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Comment by Kelli Combs (admin) on January 19, 2012 at 19:59

Sure.  Anytime.  Glad I could help.

Comment by Crystal on January 19, 2012 at 19:56

Wow, this helps so much. Thank you so much. I really appreciate it.

Comment by Kelli Combs (admin) on January 19, 2012 at 19:43


                                               I N D E X

    JANUARY 11, 2012

 

    WILLIAM JONES

   EXAMINATION                              PAGE

                    (BY MR. JONES)               6

                   (BY MS. ROBINSON)          103

                  




   QUESTIONS NOT ANSWERED:  PAGE   LINE

                                                        19      10
                                                        48      15
                                                        62      19
                                                        79       8                            
                                                        96      12
                                                        97      19
                              

Comment by Kelli Combs (admin) on January 19, 2012 at 19:11

Absolutely.  I do that for every question not answered whether the attorney tells me to or not.  I always have QUESTIONS NOT ANSWERED, on every transcript on the index.  You should get in the habit of doing it regardless if asked.

Above I've given you an example of what I mean.

Comment by Crystal on January 19, 2012 at 18:03

Okay. Would I put that for every question instructed not to answer?

Comment by Kelli Combs (admin) on January 19, 2012 at 17:54

I think what they mean is mark the transcript for a motion to the Court.  You need to put on the index page:

          QUESTIONS NOT ANSWERED

                 PAGE      LINE

                   33          17

Like that.  He wants you to delineate where in the transcript the witness was instructed not to answer so he/she can go to court on a motion to compel.  You just heard him wrong.

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