How to tell when you're in deposition hell
Am in Portland. In yet another hotel. Listening to myself breathe. And the fan on the bad heater blow. No kids. No Nala. No running down to the refrigerator for a midnight snack. Just stuck in this room. Preparing for another day of deposition.
After making ballpark guesses, give in. Pull up the transcripts and count the number of depositions that have been taken in this case. It's over 40. And we're still not done.
This isn't a class action. Or a mass tort. Or some national headline case. It is simply one young woman against the insurance companies of a handful of defendants.
So while this is all fresh on my mind, I figure, it's a good time to share with you some signs of being in deposition hell:
- You have to wake up before 5:00 a.m. two to three days each week in order to get to the airport in time to get through security so you can make the latest flight that can get you to the mornings' depositions.
- You forget what day of the week it is because you work on Saturday and Sunday
- You don't see your staff; you just communicate with them through your iphone, ipad, or laptop.
- The people at the rental car places don't ask if you want full protection anymore - they already know the answer.
- Same for whether you want to pay for a full tank of gas
- You have had so much practice that you know how to use the Alaskaair app
- Everywhere you drive, you are guided by that woman's voice coming from your cell phone speaker
- Most of your meals are eaten at the airport, on the plane, or in a car
- At least one meal every day is a luna bar
- At home you leave your suitcase semi-packed, in the closet
- You have to keep the suitcase in the closet, because seeing it makes the dog anxious
- Your family assumes you will be gone the next week.
- Your friends assume you will be gone until further notice
- You spend more time with the defense lawyers than with your family or friends
- Volunteer activities - like participating on boards, or running non-profit charitable organizations - all get wiped off your calendar to be replaced with depositions
- You get to spend your evenings drafting deposition outlines
- And researching
- And investigating
- And reading summaries
- And dealing with exhibits
- And keeping up with your other 40 cases
- And doing laundry if you're lucky enough to be home
- You realize a holiday is coming up and are thankful that Amazon.com exists
- You have not yet figured out when you will have time to browse Amazon.com
- You do not enter the enticing stores that line the way as you walk from your hotel to the deposition place and back.
- You can now pronounce every medical word involved in the case... perfectly
- And know what each of them means
- Predictably you come down with a cold
- You now get to work while sick
- This involves taking one 12 hour sudafed during the day, and two packs of mucinex at night
- Of course you don't sleep at night because your clogged nose keeps you awake
- You don't want to get up in the morning, but do
- Then haul a box of kleenex along with you, leaving crumpled up tissues in your wake
- And everyone in the deposition tries to sit as far away from you as possible
- You tell your daughter that you are 80% sure you can pick her up at the airport to welcome and bring her home for Thanksgiving; because you are flying in at the same time, except there is a chance the deposition might go long
- In which case, you will have to figure out someone to call so they can pick her up.
- Which makes you feel like a bad mommy.
And while you're doing all of this, at the same time, the paralegals are trying to find more available dates on your calendar, for more depositions.