1.  Do not make reservations to fly on a day you are taking a depo.
    1. The depo will go long and you will have to re-schedule your flight and incur large change fees.
    2. And/or the attorney will ask for a rough draft or daily expedite.
    3. Even if the attorney says they have a flight to catch at 3 p.m., attorneys will re-schedule their flights in a heart beat
  2. Do not take a deposition the day before you are leaving for a vacation. 
    1. You will end up working your whole vacation.
    2. Always clear at least one to two days before actual vacation to get in those last-minute rough drafts and expedite.
  3. Always check the trunk of your car before leaving the house
    1. If you do not check, inevitably you will arrive at the depo site and you will have left your laptop or writer at home
    2. Carry a spare (of everything)

                                                    i.     If you do not, you will need it

                                                   ii.     Figure out where your closest Radio Shack is at all times

      4.  Do not drink coffee on the way to the job – there should be coffee there

      5.  If the attorney is speaking slowly and clean, the depo will be super short.  If the attorney talks

          300 wpm, he will never want to take breaks and will want to go to midnight and will want a rough draft

          and expedite.


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Those are good ones.   Twice in my career I got to the job and left my writer at home.   Oh my.

always count the exhibits before you leave -- twice.   Note the last exhibit number and make sure you have it.   So what if you count five exhibits and you don't realize there are actually six exhibits.

Never assume a spelling of the deponent's name.  The name on the caption can be wrong.   Even if their last name is Smith, ask them how it's spelled.   First name John?  Ask them how it's spelled.

It's always best to keep a spare power cord in your trunk.  They can go out at a moment's notice.

Interesting stuff, Kyung.  I would never in a million years do 1, 2, or 3.  

1.  That anyone would work the day you're flying somewhere is mind-boggling to me.   I'm packing, going for a hair appointment, and catching up on things.

2.  Work the day before you leave on vacation?  And have any hope of getting the job in on time?  Take any chance with your reputation?   Again, it's packing, hair appointment and/or brows, and just generally TCB.

3.  Nothing of value stays in my trunk because having my car broken into 25 years ago was lesson enough.  Plus hearing other people's horror stories.  Who's leaving their equipment in the trunk?  Shaking my head!!

I'm big on spares, too, and also definitely cheap out on coffee in favor of getting it free!

I know I sound bitchy here but anyone who does 1, 2, or 3 just loves misery.  Talk about creating your own problems!

 I do carry the extra power cord.  I also have my laptop when at home plugged into its own power cord that stays at home, and I have an additional power cord that travels with my to-go bag (separate from my backup in case this one goes bad suddenly).

I keep meaning to put a "car bib" in my car because I have splashed ice tea on my white shirt and, worse, one time where we had a very short lunch break that consisted of driving through a nearby drive-through, catsup from a hamburger.  I actually had a shirt on that I could wash out (didn't get it out), so I was able to turn it around and worked with a wet spot on my back the rest of the afternoon.


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