March 31, 2015

June 2003 - How Do You Define Drunk?

From Judge Buddie J. Hahn, Texas Bar Journal, Vol. 50, No. 11 — December 1987.

Q. On the day that Twine was shot, were you intoxicated?

A. I definitely was not.

Q. Had you been drinking that day?

A. I drank a few beers.

Q. How many beers did you drink?
A. About thirty (30).
Q. And you were not drunk?
A. No.

Q. What is your definition of drunk?

A. Drunk is when you fall down and you can’t get up.

March 30, 2015

October 2002 - How Far Did You Go In School?

From John E. Haught of Beaumont, this excerpt from the plaintiff’s deposition.

Q. Where is your place of birth?

A. The hospital in Kountze, Texas. That’s the hospital I was born in.

Q. How far did you go in school?

A. I’m not sure. Just in Silsbee. Approximately estimating about eight miles or so.

March 25, 2015

April 1996 - Did They Really Say That?

From Joe and Ann Hathaway of Midland (who proofread depositions for Patricia Reid, court reporter, CSR), this deposition excerpt:

Q. How long were you the manager of this place in Longview?

A. One week.

Q. What happened after that? Where did you go?

A. I quit my job and went nowhere and stayed there ever since.

March 24, 2015

October 2006 - How To Respond to a Demand Letter

Marsha E. Rule of Tallahassee, Fla., sent me this marvelous letter that her former law partner (Jim Locke, now a county court-at-law judge) received in response to a demand letter — which Marsha has saved for 20 years.


Please be advised that I represent Enterprise Drilling & Manufacturing Co., Inc., and that they went horribly broke and the banks took back all the rigs, and there is a big deficiency, and there is a big bunch of unpaid and unsecured trade debt and the principal of the corporation is in bankruptcy and if you want a judgment against Enterprise, you can have it.

If you want more details, please feel free to call. With best regards, I remain,

Very truly yours,
Vernon N. Reaser, Jr., Reaser & Wall

March 23, 2015

January 1999 - Revenue and Safety

From William E. "Gene" Storie of Austin - Gene is the assistant chief of the Taxation Division in the Texas Attorney's office - this excerpt from his deposition of the other side's expert.

Q. From your understanding of this lawsuit, is it about pipeline safety?

A. Not directly.

Q. Do sales of gas to consumers deal with safety considerations?

A. Yes.

Q. What is the relation between revenue and safety?

A. If you deliver gas in a three-ounce meter at 200 psi and you blow the house up, your revenue goes down.

[Heavy laughter by everyone, then ...]

Mr. Bernal: You asked him.

Mr. Storie: I think I did ask that.