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Deposing a pro se litigant tomorrow: should I object to nonresponsive answers?

This guy is a tard who will flat out refuse to answer questi...
Brass Cerebral Public Bath Headpube
  04/25/18
if you sense the pro se PLaintiff will not cooperate, you mi...
nofapping massive mad cow disease lodge
  04/25/18
Is there any point in objecting to the answer except to unne...
Brass Cerebral Public Bath Headpube
  04/25/18
I had never even heard the term "certify the question&q...
Pearly comical chapel
  04/25/18
cr. is this some shitlaw flame?
Poppy menage
  04/25/18
Some half-assed googling suggests it is a regional thing roo...
Pearly comical chapel
  04/26/18
sounds like something retarded like 'the usual stipulations'
Poppy menage
  04/26/18
...
Bespoke dark church building weed whacker
  04/25/18
he means just read back the question and answer so he can ha...
bateful godawful double fault sex offender
  04/25/18
Tell judges secretary you have pro se deponent tomorrow (so ...
Fluffy theater stage patrolman
  04/25/18
Depends. If you ask him substantive questions and he refuses...
Mustard elastic band trailer park
  04/25/18
This is more of a "plaintiff doesn't want to admit he d...
Brass Cerebral Public Bath Headpube
  04/25/18
I would just focus on confirming testimony. If the issue is ...
Autistic corn cake
  04/25/18
ty
Brass Cerebral Public Bath Headpube
  04/25/18
...
Mildly autistic twinkling point
  04/25/18
...
Elite partner rehab
  04/27/18
Ask him lots of questions about his citizenship status
Diverse citrine theater brethren
  04/25/18
So what kind of case did this asshole file?
effete sanctuary
  04/26/18
The essential elements of the claim are "das racis"...
Brass Cerebral Public Bath Headpube
  04/26/18
...
Brass Cerebral Public Bath Headpube
  04/26/18
...
Pearly comical chapel
  04/27/18


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Date: April 25th, 2018 9:37 PM
Author: Brass Cerebral Public Bath Headpube

This guy is a tard who will flat out refuse to answer questions. I already had to file a motion to compel because he refused to answer interrogatories and admissions, and will almost certainly have to do the same when when I depose him. If he responds with some bullshit spiel about some unrelated topic do I object to the answer as nonresponsive and ask the court reporter to certify the question and response so I can use it in my MTC? Never had to deal with this bullshit before since every deponent I've ever dealt with has had competent representation.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921180)



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Date: April 25th, 2018 9:40 PM
Author: nofapping massive mad cow disease lodge

if you sense the pro se PLaintiff will not cooperate, you might first advised the Plaintiff that we will have no choice but to seek court intervention. This scares some pro se's and gets them to see the light. But, if that doesn't work, just certify the questions as clearly as possible. you will appreciate the work up front as you begin drafting your motion to compel the testimony.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921198)



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Date: April 25th, 2018 9:52 PM
Author: Brass Cerebral Public Bath Headpube

Is there any point in objecting to the answer except to unnerve him?

I've already advised him many times of the consequences for failing to answer and judge has granted my MTC on written discovery, though his deadline hasn't lapsed yet.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921256)



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Date: April 25th, 2018 9:55 PM
Author: Pearly comical chapel

I had never even heard the term "certify the question" until your post.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921272)



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Date: April 25th, 2018 11:20 PM
Author: Poppy menage

cr. is this some shitlaw flame?

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921929)



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Date: April 26th, 2018 10:39 AM
Author: Pearly comical chapel

Some half-assed googling suggests it is a regional thing rooted in older versions of rules.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35923854)



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Date: April 26th, 2018 1:13 PM
Author: Poppy menage

sounds like something retarded like 'the usual stipulations'

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35924746)



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Date: April 25th, 2018 11:34 PM
Author: Bespoke dark church building weed whacker



(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35922006)



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Date: April 25th, 2018 11:41 PM
Author: bateful godawful double fault sex offender

he means just read back the question and answer so he can have a clean copy of it for some motion or whatever he's going to do.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35922052)



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Date: April 25th, 2018 9:45 PM
Author: Fluffy theater stage patrolman

Tell judges secretary you have pro se deponent tomorrow (so judge will be sure to dodge your call to chambers when he's fucking around w answers.)

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921223)



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Date: April 25th, 2018 9:51 PM
Author: Mustard elastic band trailer park

Depends. If you ask him substantive questions and he refuses to answer, or goes on some irrelevant tangent, you can use that in an MSJ. "Plaintiff was asked to specifically list all instances of [whatever] and was unable to identify a single concrete example. "

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921254)



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Date: April 25th, 2018 9:53 PM
Author: Brass Cerebral Public Bath Headpube

This is more of a "plaintiff doesn't want to admit he did some bad shit" kind of thing.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921264)



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Date: April 25th, 2018 10:01 PM
Author: Autistic corn cake

I would just focus on confirming testimony. If the issue is why he went to McDonald's, you ask "Why did you go to McDonald's?" And if he says "for a sandwich," you just drill down and always ask "Are there any other reasons?" Confirm he has nothing. If he is combative remind him non-responsiveness is not a grounds not to answer. Don't be afraid to call the court if he is a true dickhead. The threat may keep him in line. And most important, if he refuses to answer anything other than on privilege grounds LEAVE THE DEPOSITION OPEN. When you are winding down just say we are done today but I am leaving this deposition open in light of your refusal to answer questions on relevance grounds.

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921319)



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Date: April 25th, 2018 11:18 PM
Author: Brass Cerebral Public Bath Headpube

ty

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921914)



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Date: April 25th, 2018 11:35 PM
Author: Mildly autistic twinkling point



(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35922011)



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Date: April 27th, 2018 5:11 AM
Author: Elite partner rehab



(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35929828)



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Date: April 25th, 2018 11:31 PM
Author: Diverse citrine theater brethren

Ask him lots of questions about his citizenship status

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35921991)



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Date: April 26th, 2018 1:17 PM
Author: effete sanctuary

So what kind of case did this asshole file?

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35924757)



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Date: April 26th, 2018 1:18 PM
Author: Brass Cerebral Public Bath Headpube

The essential elements of the claim are "das racis"

(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35924765)



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Date: April 26th, 2018 3:09 PM
Author: Brass Cerebral Public Bath Headpube



(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35925844)



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Date: April 27th, 2018 4:56 AM
Author: Pearly comical chapel



(http://www.autoadmit.com/thread.php?thread_id=3960077&forum_id=2#35929801)