How to stay awake during a boring deposition
How to stay awake during a boring deposition

Sometimes the hardest thing to do in a deposition – is stay awake.

Give me an obnoxious opposing counsel or difficult witness any time. At least the deposition will be lively and fun.

Today, ten of us are in my firm’s conference room. The videographer is at one end of the conference table. At the other sits the witness. In back of him is a neutral screen. It blocks out the angels frolicking on the old antique sideboard that usually dominates that end of the room. The camera is pinned on his face. He will become the ultimate talking head. A jury will hear but never see the rest of us.

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Karen Koehlerdeposition
There is no greater sorrow

She opens the door before I knock.  I walk up the three pristine wooden steps and am inside.

Please, she says, and motions for me to take the royal blue recliner.  She sits near me on the couch.  There is not much bric a brac.  No little tables cluttering the narrow path that runs down the side of her slender home.  It is a white rectangle.  I can see the bedroom at the other end.  The kitchen is in between.  On top of the refrigerator is a pottery piece of three very green and large smiling frogs.

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Karen Koehlerwrongful death
Escape of the Goblin
Escape of the Goblin

Am being good patient non-wiggling member of audience at the convention.  For several hours.  It is the Luvera Seminar without Luvera (dear Paul please get well).  Another Paul (Stritmatter) my partner, is playing the role of host to a rapid fire panel of speakers.

Paul tells a story to illustrate the point that jurors always like him the best of anyone in the courtroom.  He says he works hard to be professional and nice and liked the best.  And over time whether inside or outside of the courtroom, it is a habit that has stuck.  He is a very pleasant and likeable fellow.

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Karen Koehlerlawyer convention, public speaking, wsaj
On Winging It.

Have to resist rolling eyes when people say: so you're going to wing it.  In mind see chicken flapping wings with feathers flying everywhere.

Have finished lovely run.  Am a bit late so go directly to the seminar registration desk and pick up materials.  Head to elevator on way to room for a bit of a wash and change.

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Karen Koehlerpublic speaking, lawyer convention
Where's my biscotti
Where's my biscotti

Eagerly open the door to the hotel and rush over to the little table in my room.  There's the candle and right next to it should be the chocolate covered biscotti.  Last night found it in the little goodie bag left by one of the convention sponsors.  Didn't eat it then, but was saving it for a moment just like right now.  Except there is no biscotti.

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Karen Koehlerfamily, lawyer convention, traveling lawyer, wsaj
The Alpha in Deposition
The Alpha in Deposition

Nala likes me to do her bidding.  She takes me for her walks.  She puts her head or paw on my foot when we are sitting here in the office.  We will have staring contests which she almost always wins before I give up and blink.  Am okay with that.

Could have chosen to follow the instructions from the doggie obedience school (who had Nala trained perfectly for an entire month before we undid everything).  But was happier with letting Nala's own perky personality rule the day (and us).

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Karen Koehlerdeposition, nala the brittany spaniel, objections
Packing, whacking, and a sick dog

My toe is throbbing and I suppose I should tell you why.

Am also not going to edit this blog.  You’ll see it needs to be.  The p key just fell off the lapto.  In order to hit the p I have to pause and touch it just perfectly which is a real pain.  It isn’t actually a key anymore, just a little blue nub.   All missing letters will be pees.  Sure hoe Ryan can fix this in the morning.

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Karen Koehlerfamily, lawyer life, nala the brittany spaniel
The Farewell Run
The Farewell Run

Run out the door, down the driveway turn left.  Am going to say goodbye to the neighborhood that has been my family’s world for the past 21 years.

It is the first bona fide over 80 degree day of the year.  6:30 in the evening.  Too hot for Nala.  Cross the street, and head into the next subdivision.  A man is power washing his driveway.  A familiar car goes by – ex-husband and his wife.  They turn at the next street.  We live close by.

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Karen Koehlerfamily
A trial lawyer's plane travel strategies.
A trial lawyer's plane travel strategies.

Actually the headline is a bit misleading because it is not possible to ever actually like the process of flying on a commercial airplane – in coach.  But there are ways to make it bearable.  If things don’t go horribly wrong that is.  There is always THAT.  The element of “what if” to make things spicy.

Check in online as soon as am able.  Check to see if a better seat is available. Typically will cut things a little close when heading to the airport.  (This article won’t discuss the times have cut them too close.)  Don’t like waiting.  Bad impatient person.

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Karen Koehlerlawyer schedule, traveling lawyer
Worst lawyer speeches probably ever

How can trial lawyers be such bad public speakers.

Oh, this is a snarky topic.  Should not be critical of people who volunteer their time and talent to help others .   Is there a benefit in publicly venting in this way.  Tsk tsk.

Am here at the AAJ convention in NYC.  Sitting in seminar and am only not bored, because am engaging in self-indulgent venting.

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Karen Koehleraaj, lawyer convention, public speaking
Running in Central Park
Running in Central Park

Am so excited to run in Central Park.  Can hardly stand it.

Out the door of the Hilton, to the left and according to the concierge, will run straight into the park.   It is gorgeous, barely muggy out and very sunny.  Weave in and out of the people strolling down the street.  Give in to peer pressure and jaywalk/jog terribly until arrive at the massive green belt.   Need to get inside.  Way is blocked by busload of Japanese tourists.  And a lineup of horse drawn carriages.  Make it inside.

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Karen Koehlerrunning, traveling lawyer
Blowing into Split and hiding from the mankinis
Blowing into Split and hiding from the mankinis

Phone rings at 7:10.  They haven’t unlocked our connecting door yet so it is Noelle seeing if we are ready.  Need to be in Theater to be sent out for walking tour at 7:45.   Crud.  Turn on fast mode.  Do everything needed to get ready, sharing one yard square bathroom w/Cristina.  7:25.  Realize, no time to eat breakfast.  7:30. Unpacking purse and packing beach bag.  7:35.  On mission to get up to 9th floor, get beach towels, fill water bottle and get fruit. 7:40. Discover towel stand isn’t open.

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Karen Koehlerfamily
Running in Venice
Running in Venice

Out the door, down the cobbled street to the left a few feet, under the archway and am in St. Marco’s Piazza.   The weather is perfect at barely 70.  In honor of being in Italy,  Ipod is filled with songs from…why Madonna of course.  Starts off with Lucky Star.  Am getting in the Venetian spirit.

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Karen Koehlerrunning
The glamorous life goes to Venice
The glamorous life goes to Venice

We do the math.  It will be way cheaper for us to have airport shuttle service than to leave our car.  Cristina makes the arrangements. An SUV is ordered.  Ding Dong.  Car is here. What happened to the SUV.   A white stretch limo has come to whisk us away.

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Karen Koehlerfamily
Defense Medical Exam Warning Letter to Clients
Defense Medical Exam Warning Letter to Clients

What kind of a doctor can make half a million bucks a year not even treating a patient?  Why an insurance paid defense medical examiner of course.  Not all of these docs are completely sold out.  Some actually practice medicine and do these exams as a (well paid) hobby.  But there is quite a list of not so lovely characters doing DMEs to fund their lifestyles of the rich and famous.

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Karen Koehlerdefense medical examiners, insurance, personal injury
The last graduate
The last graduate

Noelle graduated from high school yesterday.   Somewhere inside me there is a frantic primal scream waiting to get out.  It doesn't seem possible.

No more babysitters to juggle so I can go to work.
Or teachers' names to pretend to remember.
No more PTSA announcements to scan.
Or soccer and tennis games to attend.

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Karen Koehlerfamily
How does a trial lawyer take a vacation
How does a trial lawyer take a vacation

Was at a retreat recently where we took a personality test.  Several of the questions dealt with things like spontaneity.  Are you the type to make plans in advance or go with the flow.  In other words - can you jump on a plane with a moment's notice or are you the stodgy detail oriented uptight plan everything in advance boring type.

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Karen Koehlerfamily, traveling lawyer