Without further adieu, a failsafe plan to take a great deposition while avoiding career suicide:
Step One: Have an incredibly important job related function on a Friday.
This can either be a trial, major deposition, motion argument or the like. It’s importance cannot be understated.
Step Two: Get together with friends for an innocuous dinner on Thursday.
In my case it was the likes of Daisy, her husband and Legally Fabulous. In this step, it is key to stop at the local alcohol provider and find high end alcohol (in our case it was Hendrick’s Gin) on super sale. Purchase. Have said husband announce “Let’s get drunk” or something to that effect. Head to Casa de Libation. Drink.
Step Three: Finish old bottle of Hendrick’s gin (about a quarter bottle), finish new bottle, drink Tequila while Daisy’s husband “catches up” on the gin and tonics. Drink Macallan’s 15 Year Old Single Malt Scotch when Gin runs out. Chase with a beer. Pass out.
Never said I was smart.
Step Four: Shockingly wake up with a hangover as Daisy is making breakfast.
I wanted to die. Then I showered. I still wanted to die, but I was less stanky.
Step Five: Commence boozy walk of shame to the office.
In this case it was a cab ride. I couldn’t walk nor could I stand public transportation. The world was spinning. Perhaps I was still drunk.
Step Six: Arrive at the office without being seen.
It helps when you know your bosses won’t be in until much later in the day. It also helps when you have a friend in the office that kindly tells you that you are covered in the stench of booze. I borrowed his aftershave to cover the gin smell seeping from my pores. It’s at this point that you need to begin drinking every non-alcoholic beverage you can find as quickly as possible.
Step Seven: Survive the dry heaves.
I’ll say that I was in the bathroom at the same time as one of my friends during his morning constitutional. That helped. It’s best not to be alone when attempting to void the contents of your stomach while wearing a $1,000 suit.
The critical element here is that the deposition is far enough away from your office but close enough to your home that you can (a) leave the office with enough to go home beforehand and (b) call the opposing counsel and ask them to delay the deposition. In this small stay of execution, you can take a shower to get the smell of despair and juniper berry and acquire a change of clothes.
Step Nine: Arrive at opposing counsel’s office with your inner rockstar on display
Waltz into the conference room with your sunglasses on. Empty your briefcase on the table: (1) iPad, notepad, waterbottle, vitamin water, vitamin water and vitamin water.
Step 10: Survive questioning by those in attendance
“Are you hungover?” Yes. I am hoping to avoid having to ask for a break so I can go vomit. Now shut up and answer the question.
Step 11: Rock the deposition
You’ll be amazed at how much energy you get back as you are trying not to puke all over the witness. Clarence Darrow, if he were a drunk, would have been proud.
Step 12: Finish Deposition, Return Home, Die
Simple. Now go forth and do.