Subject:  (Carney) (Zambrzycki) (Brenda Loew) ATS IS DEPOSING US (fwd)
Date:     Sat, 20 Mar 1999 084950 -0600 (CST)
From:     "Roy L. Beavers" <rbeavers@llion.org>
To:       emfguru <rbeavers@llion.org>
--------------------------------------------------


........Many, many thanks for this Deb!!!......Something worth saving!!!
(This a ***** [five star] item......guru.....)

Roy Beavers (EMFguru)
rbeavers@llion.org................
...It is better to light a single candle than to curse the darkness... 
.................PEOPLE ARE MORE IMPORTANT THAN PROFITS...............

........DO YOU KNOW OF OTHERS WHO SHOULD BE ON THIS LIST??????........

---------- Forwarded message ----------
Date: Sat, 20 Mar 1999 06:44:53 -0700
From: Deb Carney 
To: "Roy L. Beavers" 
Subject: Re: (Zambrzycki) (Brenda Loew) ATS IS DEPOSING US (fwd)

A few deposition tips from a trial lawyer-

Before the deposition:
        Before the deposition, carefully review anything that you have written
that the other side has such as letters, answers to interogatories and requests
for production.
        People are usually not expected to remember exact dates.  What is more
important is getting the sequence of events correct.  It is helpful  if you
prepare a time line in advance just to refresh your memory.
        Do not bring anything to the deposition other than what your
lawyer tells you to bring.  If you come with a batch of notes in your
hand, the other attorney will want to see them and may mark them as an
exhibit.
        Tell your attorney about anything that you feel could be
dangerous.  For example, if you have been in jail, be sure you have
explained it to your attorney.  Your attorney can not protect you if
he/she is the last to know.  Often what you are concerned about is not
that bad.

At the deposition:
    Listen carefully to the question, think  and then answer that question only.
    If you can answer with a "yes" or "no", just answer "yes" or "no"
    If your attorney thinks one of your answers needs an explanation-he or she
can ask for one when it is their turn to ask you questions.
    If you don't understand a question-don't guess-tell them you don't
understand the question.  (this is not a multiple choice quizz)
    Remember that it is the adverse lawyer's job to ask the right questions-if
they don't, do not volunteer information-this is not a press conference.
    Give your attorney enough time to object and try to avoid letting the other
attorney getting you into rapid fire questions and answers.
    Your own attorney is your defender-your attorney will fight with the other
attorney if necessary.  Do not try to fight with the adverse attorney.
    If your attorney asks you a question, there is a reason-it is probably to
clarify something you said earlier that was unclear or twisted.  Listen
carefully to your attorney's question. ( remember that your own attorney
can talk to you anytime and it won't be on the record)
    Discussions between you and your attorney are no one else's business.  They
are protected by the attorney-client privelege.
    Tell the truth.  The very worst you can do is knowingly lie about something.
    Ignorance of something is not bad.  If you don't know, tell them you don't
know.
    The adverse attorney is not just interested in answers.  The adverse
attorney will be reporting back to his client about what kind of an
appearance you make as a witness-what the jury is likely to think of you.

Many a case has been settled following depositions because the other side
found out the integrety and appearance of the witnesses against them.
    
    Juries turn on angry people, smart alecks, liars, people who
overstate, people who lecture them and phonies.
    Juries listen to honest, sincere hard working people.
    60% of all human communication is non-verbal.
    You will live through this experience and you will be O.K.  We all fear the
unknown.  Your heart may beat fast as they ask those questions about your name
and address, but then your brain will respond as you tell the truth.

If you are like most people in these EMR fights, you are a good-hearted,
concerned citizen.

Good luck.
Deb

"Roy L. Beavers" wrote:

> Utility bullies (and their lawyers)......
>
> ........Folks, I tell you "harassment and intimidation" is the name
> of the game they play.......If you can be completely STOIC and "don't
> give a damn" about it, you WILL frustrate them!!!   When they find that
> their **bullying** tactics roll off you (like water off a duck's back)
> they have exhausted their resources.......  If you have an honest
> claim against them, you should expect MOST juries to be on your side....
>
> As I said before, it is particularly helpful to get as much publicity
> as you can about their bullying tactics.....
>
> Roy Beavers (EMFguru)
> rbeavers@llion.org................
> ...It is better to light a single candle than to curse the darkness...
> .................PEOPLE ARE MORE IMPORTANT THAN PROFITS...............
>
> ---------- Forwarded message ----------
> Date: Fri, 19 Mar 1999 20:55:50 EST
> From: ZzzCathy@aol.com
> To: rbeavers@llion.org
> Subject: Re: (Brenda Loew) ATS IS DEPOSING US (fwd)
>
> My Husband and My Self have been deposed and at the last minute GTE
> cancelled the Deposition.  It cost us $1000.00 to get ready for the
> deposition (lawyers fees) and they cancelled.  I dont know why but they
> did.
>
> Our Lawyer gave us a good movie to watch before we were suppose to go It
> was really a great movie and taught us alot.  What they can do with a
> simple coment and twist it to work for them.
>
> Most important is not to quess at anything just say "I'm not sure"  Its scary
> but be strong and Pray alot.
>
> I'll let you know when and If they reschedule the date.
>
> Cathy Zambrzycki




Archive provided courtesy of WaveGuide, http://www.wave-guide.org
Reprinted with permission of Roy Beavers, http://www.feb.se/EMF-L/EMF-L.html