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Always "Keep Your Head UP" & Always Be "On Point"

My teeth were clenched tight and my feet began to wag at an increased speed while reviewing my deposition outline and the Texas’ rules furiously the night before my deposition on one of my first big cases. This task was considered important because my supervising partner had taken all of the previous depositions for this case and she usually would take them for a case of this size. I was extremely nervous but I wanted to make sure I was properly prepared for any possible scenario that could occur. After reviewing my deposition materials, I laid out my neatly ironed black business outfit, black pumps, black leather briefcase and all of my exhibits ready to go first thing in the morning. When the morning finally came, I even said a little prayer in the car on the way to the deposition. My nerves had officially turned into excitement and I was ready to “take on the world”—or the deponent for that matter.

However, when I stepped into that deposition room, opposing counsel, who I had met many times at other depositions, asked if I was the court reporter. From the time I stepped off of the elevator to the time I made it to the conference room to sit and open my laptop for the deposition, I was mistaken for a court reporter, a videographer and I was even asked by someone for coffee. I smirked silently under my breath and thought to myself that I did a lot of preparing and thinking of various possible scenarios but I did not think of a scenario in which the deponent or opposing counsel would ask me (the attorney) when the attorney would be arriving. Though a little taken aback, I kept my head up and I proceeded with the deposition.

As I proceeded, as expected by many young lawyers but especially female lawyers, opposing counsel attempted to assert absurd objections, being extremely aggressive—all while calling me sweetheart. Because I was prepared, this did not faze me. I knew the rules backwards and forwards, I knew the chronology of events for the case and I knew the answer to every question before I even asked it. When opposing counsel realized that this sweetheart, court reporter was not backing down, he changed his tone. By the end of the deposition, opposing counsel was silent.

I share this story, not to discourage young minority females, but to encourage them. Regardless of how you are treated, what name you are called or if you are underestimated, do not allow anyone or anything to ruin your performance or professionalism. I assure you that no one might have known that I was an attorney when I walked into the deposition, but they all knew when I walked out. If you are “on point” and prepared, then people respect that—whether that is at a deposition, a hearing or otherwise. To this day, I don’t know if opposing counsel made an honest mistake as an aggressive lawyer or if he was trying to take advantage and be rude to a “baby lawyer”. Regardless of his intentions, there will be situations you encounter that require you to keep your head up and stay on point.


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