The Best Deposition Answer in the History of Depositions?

The Best Deposition Answer of all Time? I don’t know but this was a good answer and it was due to preparing the client for his deposition and making sure he understood the effectiveness of story-telling. My client was asked the question, is there anything you can’t do now, that could do before the collision? His response was truthful and he used the power of storytelling to respond: The challenge was to convey how the injury changed his life in the most honest and authentic way possible. This is the paraphrased answer:

“When I was little, my parents had a garden, and I promised myself I would never have a garden when I got big. But sure enough, when I got married, we planted a vegetable garden in the backyard. You could look out the kitchen window and see it. I was proud of it. My wife and I enjoyed working out there. We planted beans, corn, tomatoes, cabbage, okra, and other vegetables. 

When the kids came along, we started to teach them how to work in the garden. It was something our family did together. I think they enjoyed it more than I did when I was a child. Every now and then on a Saturday morning, my wife would say, Daddy! Get the baskets! The children and I would grab three baskets and go to the garden and start picking vegetables. When we finished, we’d get in the car, and my wife would direct us to a particular house and we stopped, and walked up to the front porch and knocked on the door. Usually, the person that opened the door was someone who either just lost their job, was recently divorced, had lost a loved one, or had just gotten out of the hospital. We told them that we had so many vegetables we couldn’t eat them all. And we wondered if they’d help us by taking them off our hands. Lots of times the kids would go in and play with their children. Before you knew it, we all became friends. After a while, we had a nice little community there. So, I really enjoyed having that garden. But I can’t do the work anymore because of my shoulder pain.”

Don’t we need more people helping others creating good communities with good neighbors? I could imagine how that would end up at trial. I would ask my client to pretend to look out his back window and tell us what he sees….”a bunch of weeds, briars, and overgrown bushes.”  My response, “What about the garden you were telling us about?” Answer: “I can’t garden any more…so we let it go.”  This responses meets all the requirements of a good deposition answer. 1. Truthful  2. Not an exaggeration 3. Compelling 4. Demonstrates the loss to the client, his family, and the community.