Deposition Questions

Preamble: Mr./Ms. _________________, my name is ________________ and I am representing the City of Los Angeles in the matter of Conspicuous Construction vs. City of Los Angeles. The other attorney(s) is/are ______________.

I understand that you have been sworn in.

I have some questions for you. You are required by law to answer these questions to the best of your knowledge. I see that you have been cooperative and have provided counsel with copies of all reports, letters, computer files and correspondence with respect to this case.

You will note that there is a court reporter. Please speak distinctly and slowly so that the court reporter can keep up with the testimony.

Also, never begin answering a question until the question is finished. The court reporter cannot transcribe two conversations simultaneously.

Finally, attorneys may object to a question, and state it for the record, but you are still required to respond.

Do you understand?

Thank you.

Attorney 2:

Here are our questions:

1. For the record, please describe your academic and professional background.

2. I note that you have the initials CCM listed after your name. Please tell us what that means.

3. Your rates are listed as $150 per hour. That works out to a yearly salary of $312,000. How do you justify such outrageous rates?

I have nothing further.

Attorney 3:

4. (a) (this is for Michele, Eric and Elizabeth) Your graphic of the relationship of PDO to Southern California rainfall seems to show that there is indeed a relationship. To me it appears that there is a positive correlation. You already admitted that PDO values are negative lately….so what is the basis for your opinion that there is no important relationship between PDO and southern California rainfall?

(b) (Agustin)You do include a graphic that shows that the NINO3 indices have a strong relationship to southern California. Our information is that there is a stronger relationship between PDO and southern California, We think it is very curious that you contend that there is no important relationship between PDO and southern California rainfall, yet you very conveniently have chosen not to include a graphic that portrays this. Can you explain why you have chosen not to include supporting documentation in the form of a similar graphic.

5. (a) What is PDO?

(Assuming that the response is Pacific Decadal Oscillation, and ends with that)

· Alright, we know what the abbreviation expands out to, but what exactly is it?

· (Assuming that at least one of the people fumbles around) So, basically, what you are telling me is that you don’t know what the PDO is. Is that correct?

· (If there are any attempts at fumbling around here…) The bottom line is that you can’t effectively explain what PDO is, and yet you expect us to accept your interpretation about its relationship to Southern California rainfall. Is that correct?

If some reasonable attempt is made to explain PDO, then

(b) You have included supporting charts that show PDO’s lack of corresondence to LA Civic Center rainfall. Didn’t you think that charts showing the relatioinship of NINO3 to LA rainfall might have helped us out here?

6. No matter how they answer to 5, you say, in nearly a disgusted tone….

“…I get it. I guess you are the expert, after all. I have nothing further.”