May 30, 2015

May 1994 - Did She Really Say That?

From Suzanne Saenz of Houston (Suzanne is a legal assistant with Ronald W. Ryan), this excerpt from the plaintiff's deposition in a medical malpractice case.

Q. Mr. Williams, are you on any medication today?

A. Yeah. No. Just a little old pain pill; but I'm not - I know what I'm doing ...

Q. What kid of pain pill is that?

A. Let's see. What did I Tell you the name of it was, a while ago?

Def. Attny: I think you said Vicodin.

A. Vicodin. That's what it is, and it doesn't really hurt my memory.

May 29, 2015

January 1996 - East Texas Slang

From Raymond W. Cozby, III of Tyler (Cowles & Thompson), this closing argument made by his brother, Andrew J. Cozby, the prosecutor in a criminal trial in Houston:

Mr. Cozby: Members of the jury, I appreciate your patience during this trial. I'm going to be talking quick because my time is limited. If you can follow this East Texas slang I appreciate it because I'm going to be going over some important points.

Number One: What we call in East Texas — if you've ever seen a dog chasing a rabbit, sometimes they will get off on some rabbit's trail. That's a false trail that leads off in a circle. And a dog will get off on a false trail from where the rabbit really is.

Defense Attorney: Your Honor, I object to being called a dog.

Mr. Cozby: Your Honor, I except to that, I was calling him a rabbit.

May 28, 2015

July 2000 - Did They Really Say That?

From Rocky Dhir of Dallas (Rocky is one of my law clerks this year), this excerpt he discovered in a deposition in one of our recent civil trials.

Q. How was the roof [of the apartment] inspected, then: from the balconies and from the parking lot, I think you said?

A. That's correct.

Q. And that was at both projects?

A. That's correct.

Q. What did you do to observe the roofs from those locations?

A. I looked at them.

May 27, 2015

January 2002 - Did They Really Say That?

From Al Ellis of Dallas (Al is of counsel with Howie & Sweeney), this excerpt from “a routine personal injury deposition” in which he received “the final answer as to why the divorce occurred.”

Q. What was the reason for your mom’s first divorce, if you know?

A. My dad.

May 26, 2015

March 2002- And Then Things Went Downhill...

From Steven C. Laird of Fort Worth (Russell, Turner, Laird & Jones), a contribution from the trial of a medical negligence case. The excerpt is “the very beginning of the cross-examination of the plaintiffs’ nursing expert” ­ a “very attractive, statuesque nurse in her early 40’s.”

Q. All right. I don’t know why; but when I first took your deposition in Houston and even today, I get the feeling of how a dove must feel when my Russian blue cat is stalking it. Do you have cats?

A. I have two Abyssinians.

Q. Big ones?

A. Abyssinians, by nature or their breed, are small.

Q. Because of that, I’m going to try to find areas as long as I can —

A. I’m sorry. Can you clarify? You’re stating that I’m stalking you?

Q. I’m just saying, I feel like a dove in the backyard.

A. Yeah. Don’t be afraid.