5 PLAINTIFF, was duly sworn, and was examined and
6 testified as follows:
7 EXAMINATION BY COUNSEL FOR PLAINTIFF
8 BY MR. DITHERS: (01:23:04)
9 Q (01:23:20) Good morning, Ms. Doe.
10 A (01:23:24) Good morning.
11 Q (01:23:28) Have you ever had your deposition taken
12 before?
13 A (01:23:33) No.
14 Q (01:23:36) Well, let me explain a couple of the ground
15 rules. You are about to provide sworn testimony in
16 this case. What you say during a deposition is just
17 like testifying in court, except the judge is going
18 to read it, instead of listening to you speak right
19 in front of him, okay? So it's legally binding,
20 just like in a courtroom.
21 A (01:23:46) (No verbal response.)
3
1 Q (01:23:52) Which brings us to the next ground rule. I
2 saw you shake your head, but the judge won't when he
3 reads this transcript. The testimony that you
4 provide today is going to be taken down by the court
5 reporter here, and then he will type it up.
6 Anything not spoken, such as nodding or shaking your
7 head or gesturing with your hands will not be
8 recorded, and it will be as if you never said
9 anything at all. Do you understand that?
10 A (01:23:59) Yes.
11 Q (01:24:03) Good. So please, make all your replies loud
12 and clear. Now, please state your name for the
13 record.
14 A (01:24:10) Jane Doe.
15 Q (01:24:13) And can you spell that for the record,
16 please.
17 A (01:24:18) J-A-N-E D-O-E.
18 Q (01:24:20) And what is your sosh (phonetic)?
19 A (01:24:24) If it's gonna be part of a permanent record,
20 can I write that down instead of say it out on the
21 record? I know this is going to become part of a
4
1 file in the courthouse that anybody can read.
2 Q (01:24:33) Well, not just anybody, but sure, I
3 understand. Please write it down, and I'll make
4 sure nobody sees it that doesn't have any business
5 seeing it.
6 (Whereupon, the Defendant complied.)
7 BY MR. DITHERS: (01:24:45)
8 Q (01:24:50) Thank you. So are you aware that Mr. Doe is
9 suing you for custody of your cat, Ms. Doe?
7 (Whereupon, at 1:25 p.m., the
8 deposition was concluded.)
9 (Exhibits attached.)
10 (Signature NOT waived.)
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