I will always remember my first deposition. When starting out as a new attorney back in 2003, I deposed an interesting individual. After the usual admonishments and questions about his home, family, etc., I asked that tell-all question ” Have you ever been injured at work?” Without a beat, the applicant said no.

I knew that his injury was witnessed at work, but now he denied an injury. What was he trying to hide? Applicant’s attorney smelled fresh blood in the water.

I attempted to clarify, but each time I tried to ask about his injury in a different manner, I would hear “Objection, asked and answered!” Since I was getting nowhere fast, I took a break in the deposition and spoke with my senior attorney. Fortunately, he was able to get me back on my feet after we spoke with the applicant’s attorney and the deposition went forward.

Looking back, now I realize that when the other attorney began having fun at my expense, I could have begun to conclude the deposition and taken the applicant at his word, that, No, he did not have an injury at work. Case-Closed!