PMK

[Kyung]

PMK - Person most knowledgeable. Inevitably some one who really isn't that knowledgeable at all. After three hours of questioning, you'll find out that:

A) they weren't working at the company for the period in dispute
or
B) they worked there, but in a different department
or
C) they are just some poor schmuck getting thrown to the wolves.

[Diane Hickman]

I've done a few of those depos and it really is true that the PMK's are totally clueless. It's even worse if the supervisor shows up as an "other persons" in the depo and they just sit across the table staring at the deponent, who is already upset that (1) they're in a depo (2) they drag in with them all their emotional garbage and anxiety (3) they are trying to get their point across to this clueless person who usually says, "Gee, I didn't about it." Total waste of everybody's time. I had one plaintiff's attorney gleefully state before the end of the depo that she had to cut it short because she was expected at the company's Christmas party in 20 minutes, all the while her client is crying because she lost her job, was raising 3 kids in the L.A. projects, and she didn't have any money for gifts for Christmas. Needless to say, I wasn't amused, but I kept neutral and wrote the job.
Can you say "Scrooge"?

[Judy]

Must have been a Caltrans PMK.

[Carolyn C.]

So true! I've started to think this is not an accident. Attorney requests the dep of the PMK of the company; the attorney for the company decides to designate someone who is clueless, therefore rendering the dep fruitless. Seems like strategy to me.