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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...
Bronze aromatic twinkling uncleanness
  04/25/18
if you sense the pro se PLaintiff will not cooperate, you mi...
marvelous vermilion kitty
  04/25/18
Is there any point in objecting to the answer except to unne...
Bronze aromatic twinkling uncleanness
  04/25/18
I had never even heard the term "certify the question&q...
filthy scourge upon the earth ticket booth
  04/25/18
cr. is this some shitlaw flame?
passionate carnelian market
  04/25/18
Some half-assed googling suggests it is a regional thing roo...
filthy scourge upon the earth ticket booth
  04/26/18
sounds like something retarded like 'the usual stipulations'
passionate carnelian market
  04/26/18
...
frum smoky wrinkle
  04/25/18
he means just read back the question and answer so he can ha...
Mahogany goyim
  04/25/18
Tell judges secretary you have pro se deponent tomorrow (so ...
diverse orchestra pit
  04/25/18
Depends. If you ask him substantive questions and he refuses...
hairraiser principal's office quadroon
  04/25/18
This is more of a "plaintiff doesn't want to admit he d...
Bronze aromatic twinkling uncleanness
  04/25/18
I would just focus on confirming testimony. If the issue is ...
Magenta menage jew
  04/25/18
ty
Bronze aromatic twinkling uncleanness
  04/25/18
...
coiffed site reading party
  04/25/18
...
vengeful spot blood rage
  04/27/18
Ask him lots of questions about his citizenship status
racy domesticated stag film
  04/25/18
So what kind of case did this asshole file?
Balding house-broken laser beams lodge
  04/26/18
The essential elements of the claim are "das racis"...
Bronze aromatic twinkling uncleanness
  04/26/18
...
Bronze aromatic twinkling uncleanness
  04/26/18
...
filthy scourge upon the earth ticket booth
  04/27/18


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Date: April 25th, 2018 9:37 PM
Author: Bronze aromatic twinkling uncleanness

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: marvelous vermilion kitty

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: Bronze aromatic twinkling uncleanness

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: filthy scourge upon the earth ticket booth

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: passionate carnelian market

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: filthy scourge upon the earth ticket booth

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: passionate carnelian market

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: frum smoky wrinkle



(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: Mahogany goyim

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: diverse orchestra pit

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: hairraiser principal's office quadroon

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: Bronze aromatic twinkling uncleanness

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: Magenta menage jew

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: Bronze aromatic twinkling uncleanness

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: coiffed site reading party



(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: vengeful spot blood rage



(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: racy domesticated stag film

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: Balding house-broken laser beams lodge

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: Bronze aromatic twinkling uncleanness

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: Bronze aromatic twinkling uncleanness



(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: filthy scourge upon the earth ticket booth



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