Not surprisingly, not to name any names, but people frequently lie under sworn oath, including in depositions. So you have to appreciate, as did the opposing lawyer, the sincere honesty of this deponent.
[Opposing Lawyer] was deposing my 19-year-old client. Her dad died in a collision near Hope, Arkansas on I-30. He had been in and out of prison all of his life.
My opponent was asking her about her dad’s habits:
Q. Did he use drugs?
A. He smoked marijuana.
Q. Okay. You know how often?
A. After he went to report for probation.
Q. Oh, my goodness. You are one honest person, young lady.
Thanks to Jim Jackson, former student and now all-star lawyer.
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