EFTA02004973.pdf
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To: jeevacationiagmail.comfjeevacation©gmail.comb
jeevacationegmail.comueevacationepgmail.com]
From: Jean Luc Brunel
Sent: Wed 10/3/2012 11:59:53 PM
Subject: Fw: maintaining composure/behavior at deposition
From: Jonathan David
Sent: Wednesday, Oct r , :
To: Jean Luc Brunel; Jeff Fuller
Subject: Re: maintaining composure/behavior at deposition
Jean-Luc,
Also, I know I don't have to say it, but if and when talks shit, it will look bad if you
interject. Let her hang herself, and quietly ask me to declare a recess (break), and we'll re-attack.
Judges reading transcripts generally disapprove of outbursts like "Oh, that's a lie. She's lying!" or
something like that. She knows that we know that she's lying, and it's up to me to ask her for
each lie: "What do you have in writing that corroborates what you are saying? Do you have
photos? What witnesses (names] will corroborate what you are saying?" etc...
It's not going to be pretty. She is going to attack on every possible ground. But at issue in this
case is (technically) only her embezzlement, and her defenses to that -- which include whether she
has tried to create a situation where she can blackmail you into dropping the case.
My office is at the street address below. 10 a.m. and sorry to say you have to park on the street.
There will be plenty of time to address all questions. There is also the possibility that her
attorney will instruct her not to answer certain questions and will could have to adjourn, then go
to the judge, and then come back after a ruling... We just don't know how it will play out until the
questions are asked...
See you
-JD
The Law Office of
Jonathan N. David, Esq., P.A.
1550 Madruga Ave., Suite 201
Coral Gables, FL 33146
EFTA_R1_00503526
EFTA02004973
jeevacationegmail.comueevacationepgmail.com]
From: Jean Luc Brunel
Sent: Wed 10/3/2012 11:59:53 PM
Subject: Fw: maintaining composure/behavior at deposition
From: Jonathan David
Sent: Wednesday, Oct r , :
To: Jean Luc Brunel; Jeff Fuller
Subject: Re: maintaining composure/behavior at deposition
Jean-Luc,
Also, I know I don't have to say it, but if and when talks shit, it will look bad if you
interject. Let her hang herself, and quietly ask me to declare a recess (break), and we'll re-attack.
Judges reading transcripts generally disapprove of outbursts like "Oh, that's a lie. She's lying!" or
something like that. She knows that we know that she's lying, and it's up to me to ask her for
each lie: "What do you have in writing that corroborates what you are saying? Do you have
photos? What witnesses (names] will corroborate what you are saying?" etc...
It's not going to be pretty. She is going to attack on every possible ground. But at issue in this
case is (technically) only her embezzlement, and her defenses to that -- which include whether she
has tried to create a situation where she can blackmail you into dropping the case.
My office is at the street address below. 10 a.m. and sorry to say you have to park on the street.
There will be plenty of time to address all questions. There is also the possibility that her
attorney will instruct her not to answer certain questions and will could have to adjourn, then go
to the judge, and then come back after a ruling... We just don't know how it will play out until the
questions are asked...
See you
-JD
The Law Office of
Jonathan N. David, Esq., P.A.
1550 Madruga Ave., Suite 201
Coral Gables, FL 33146
EFTA_R1_00503526
EFTA02004973