Dear Bill,

Here is my best deposition story.

When taking the deposition of my client, opposing counsel began badgering my client.  He raised his voice.  He slapped his hand on the table.  He pointed his finger in my client’s face.  I had enough so I said, ” Let the record reflect that Mr. (opposing counsel) has raised his voice.  Let the record reflect that Mr. (opposing counsel) has slapped his hand on the table.  Let the record reflect that Mr. (opposing counsel) has pointed his finger in my client’s face.”  I then told him on the record that my client was here to answer all of his questions, but if he continued to badger my client we were leaving.

To my surprise, he changed completely.  He did not apologize, but he became very polite, even friendly.  At the end of the deposition we shook hands and departed as friends.

Tom