Fw: maintaining composure/behavior at deposition

From: Jonathan David

Sent: Wednesday, October 03, 2012 07:58 PM

To: Jean Luc Brunel; Jeff Fuller

Subject: Re: maintaining composure/behavior at deposition

Jean-Luc,

Also, I know I don't have to say it, but if and when talks shit, it will look bad if you interject. Let her hang herself, and quietly ask me to declare a recess (break), and we'll re-attack. Judges reading transcripts generally disapprove of outbursts like "Oh, that's a lie. She's lying!" or something like that. She knows that we know that she's lying, and it's up to me to ask her for each lie: "What do you have in writing that corroborates what you are saying? Do you have photos? What witnesses (names] will corroborate what you are saying?" etc...

It's not going to be pretty. She is going to attack on every possible ground. But at issue in this case is (technically) only her embezzlement, and her defenses to that -- which include whether she has tried to create a situation where she can blackmail you into dropping the case.

My office is at the street address below. 10 a.m. and sorry to say you have to park on the street. There will be plenty of time to address all questions. There is also the possibility that her attorney will instruct her not to answer certain questions and will could have to adjourn, then go to the judge, and then come back after a ruling... We just don't know how it will play out until the questions are asked...

See you

-JD

The Law Office of

Jonathan N. David, Esq., P.A.

1550 Madruga Ave., Suite 201

Coral Gables, FL 33146