Who here has every been the subject of a deposition? Who here has ever acted like jerk during a deposition towards an arrogant attorney from the other side?
Great! It's not just me. Just one more thing we have in common...
A young HR capitalist was once the subject of a deposition featuring an arrogant, condescending attorney on the other side. The young HR capitalist reacted in such a negative way that the attorney on his side had to call for a break and counsel the young HRC to stop being a d##k to the other side - even though they had it coming.
Favorite plays from the deposition playbook of mine the young HRC included -
--only answering questions in yes/no format when the question clearly called for more...
--answering questions framed in a negative tense (so you don't believe that manager...) "yes". Because in my mind I'm saying yes to your statement, not going with the informal flow. This is a formal event, right?
--not giving enough details on process because I can't clearly define it as it works a variety of ways - although there is a certain way it's supposed to work, but you didn't ask me that, did you?
No wonder that attorney called for a break during the young capitalist's deposition.
That's why the notes below from a deposition of Google co-founder Larry Page are so fun. Page was recently deposed by attorneys representing Uber in a lawsuit filed by Google related to the allegation of stolen IP from self-driving car company Waymo. Take a look at the notes below from the deposition Business Insider and see my notes in brackets and all caps:
The transcript is full of examples of Page responding tersely to questioning, such as this exchange:
Uber: Google invested in Uber, correct?
Uber: Do you recall when?
Page: My answer is yes. (PRO MOVE - JUST ANSWERING THE QUESTION YES/NO. DID THEY WANT MORE? SURE, BUT YOU ANSWERED THE QUESTION. SUCKS TO BE THEM)
Page said he wasn't familiar with how Google stores source code:
Uber: Do you know the way that Google typically retains things, like source-code materials and design specifications, and things like that?
Page: Yeah, I'm not that familiar with how we do that.
Uber: Is there an online repository, or do — do you even know that?
Page: I mean, there's some code-based repository thingy. (THE SENIOR LEVEL "THINGY" OR "DOHICKIE" REFERENCE. WELL PLAYED)
And this feisty exchange:
Uber: You're not familiar with the details of the trade secrets that are at issue here?
Page: Yes. (ANSWERING A QUESTION CALLING FOR A SIMPLE NO WITH A YES. IT'S NOT LARRY'S PROBLEMS THAT THEY PHRASED IT IN A WAY THAT HE COULD HAVE FUN WITH. "THAT'S CORRECT" IS BORING. "YES" IS MUCH MORE FUN)
Uber: You don't know, for example, what the trade secrets are that Uber allegedly misappropriated?
Page: No, I do not.
Uber: Whenever it was that you learned — let me make sure I'm clear on this. You don't remember, sitting here today, when you learned or how you learned that Uber may have misappropriated Google or Waymo trade secrets. Is that right?
Page: That's correct. (MISSED OPPORTUNITY - HE COULD HAVE SAID YES)
Uber: And you don't remember how you learned?
Page: I mean, that's correct, yes.
Uber: Did you authorize the filing of the lawsuit against Uber?
Page: I mean, I'm certainly aware of it, yeah, and then allowed it to proceed, I suppose. I'm not sure I authorized it. I'm not sure that's the right word.
Uber: Well, could a lawsuit of this magnitude be filed without your consent and approval?
Page: I mean, I guess I'm not — I'm the CEO of the company — parent company of Waymo, and Waymo operates more or less as an independent company.
Uber: Is Waymo authorized to file a lawsuit like this on its own without even consulting you?
Page: I mean, I don't know all the details of that. (I'M FLYING AT 100,000 FEET PEOPLE. YOU REALIZE I COULD BUY YOUR FIRM TODAY, RIGHT? I'M NOT TALKING ABOUT GOOGLE BUYING IT, I MEAN ME PERSONALLY)
Pros moves all the way around. Holla if you've ever been a barrier to a successful deposition - as the actual subject of that deposition.