• Pretty mild, actually.

    For those not familiar with SSRN, you have to look for a download link in the upper left corner to read the paper.

  • I’ve experienced far worse. I would have considered myself lucky if opposing counsel had merely followed the tricks contained in the article. In a civil suit alleging wrongful termination, breach of contract, and breach of fiduciary duty, we had some pretty colorful questions that were far beyond the scope of relevance come up at deposition. The termination had nothing to do with sexual harassment, yet I was asked about my sexual practices and for full names of sexual partners. My attorney objected, but due to time constraints, was unable to get a judge on the phone to sustain the objection. I ended up answering the question, though I was quite angered by the fact that I didn’t have the right to not answer it.

  • If you liked this article, another similar one also written by Neil Dilloff has just been posted on SSRN: “Deposition Tips for New Litigators,” at