📄 Deposition procedures — Tuesday, November 5, 1996
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C:\DEPT103\CIVIL\1996\NOV\5\DEPOSITION-PROCEDURES.DOC
TRIAL
▲ Day 9 of 57

Deposition procedures

Date: Tuesday, November 5, 1996 • Utterances: 24
The court prepares to play a video deposition of witness Brenda Vernich, estimated at 53 minutes. Counsel briefly discuss the identity of a third attorney (Mr. Borger) who represented the witness at the deposition, and reach a housekeeping agreement that the court reporter need not transcribe the video playback and that all objections in this deposition can be deemed overruled.
1 THE COURT:

You may proceed.

Who is this going to be?

2 MR. PETROCELLI:

Brenda Vernich, Your Honor.

3 MR. LEONARD:

Your Honor, at this deposition, Mr. Kelly was asking the questions; I was also asking questions; and I believe, just for the benefit of the Court, there was a third attorney I think who may have asserted an objection. I think that was someone representing the witness.

4 MR. KELLY:

Borger.

5 MR. LEONARD:

So it's clear to the jury who the parties were.

6 THE COURT:

Who was that person?

7 MR. LEONARD:

There was an attorney representing the witness.

8 MR. KELLY:

Mr. Borger, B-O-R-G-E-R, who was there on behalf of the witness testifying, Your Honor.

9 THE COURT:

All right.

10 THE COURT:

How long is it?

11 MR. KELLY:

About 45, 50 minutes, Judge.

12 THE COURT:

Huh?

13 MR. KELLY:

45 minutes.

14 THE COURT:

45 minutes? Okay.

15 MR. KELLY:

I'm sorry; 53 minutes full play time, Judge.

16 THE COURT:

Jury ready for 53 minutes?

17 (Videotape starts to play.)
18 THE COURT:

Can you stop that for a second.

Counsel have an agreement with the record that -- whether or not you want the reporter to take this?

19 MR. KELLY:

I don't think it's necessary.

20 MR. LEONARD:

I don't think it's necessary.

21 MR. KELLY:

As long as we agree that the transcript of the deposition can be used, if necessary, in the future for evidence, sure.

22 MR. PETROCELLI:

We have an agreement that all the objections can be deemed overruled.

KEY QUOTE
23 MR. LEONARD:

In every videotape?

24 MR. PETROCELLI:

No, no. In this one.

Temperature

routine

Key Quotes (2)

Daniel Petrocelli
We have an agreement that all the objections can be deemed overruled.
Unusual stipulation suggesting the deposition objections were not disputed enough to require the court to rule on them individually.
Dan Leonard
In every videotape?
Leonard's quick clarification reveals this was not a blanket agreement — it applied only to this specific deposition.

Evidence (1)

Informal
Video deposition of Brenda Vernich, approximately 53 minutes
introduced/played for jury

Notable Exchanges (1)

Daniel PetrocelliDan Leonard
Petrocelli proposes all deposition objections be deemed overruled; Leonard immediately asks whether that applies to all videotapes before Petrocelli clarifies it's only this one.
strategic

Witness Demeanor

(Videotape starts to play.)

Objections

None recorded
Proceeding 8145 • 24 utterances
Civil Trial
Department 103
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📂 NOV 5, 1996 📄 Deposition procedures
NOV 5, 1996 KRT DvH TD