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033110bysiewicz

033110bysiewicz

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Publicado porHelen Bennett
This is the first of three parts of a transcript of a deposition Conn. Sec. of the State Susan Bysiewicz gave to Republican lawyers as part of her lawsuit to determine if she is qualified to run for attorney general.
This is the first of three parts of a transcript of a deposition Conn. Sec. of the State Susan Bysiewicz gave to Republican lawyers as part of her lawsuit to determine if she is qualified to run for attorney general.

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Published by: Helen Bennett on Apr 06, 2010
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10/25/2011

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18 Q Is it okay if I call you Madam Secretary? I

19 don't really know the right title.

20 A Go right ahead. That's fine.

21 Q Okay. Great. Madam Secretary, my name is

22 Eliot Gersten. I represent the intervening defendant

23 in this case. I'm going to ask you a series of

24 questions. I'm hoping you can give me the answers.

25 Any time you have a problem with any of my questions,

Brandon Smith Reporting

5

1 feel free to speak up and say, I don't understand,

2 otherwise I'm going to assume that you do, in fact,

3 understand. Is that instruction understood by you

4 now?

5 A Yes.

6 Q Great. Thanks. The next instruction I'm

7 going to let you know about is any time you want to

8 take a break, either indicate I've got to take a short

9 break, go ahead, this is not an endurance contest. Ask

10 for a cup of water, coffee, I'm not here to try to see

11 how long one of us can last until we have to breakdown.

12 Okay?

13 A Great.

14 Q Great. You're the plaintiff in this action.

15 A Yes.

16 Q Great. And you -- did you review any

17 documents in preparation for your deposition today?

18 A I did.

19 Q Okay. Would you identify the documents you

20 reviewed in preparation of your deposition today?

21 A They would be documents in a notebook given

22 to me by my attorney.

23 Q Okay. And what was the contents of the

24 documents that you looked at in preparation for your

25 deposition today?

Brandon Smith Reporting

6

1 A They would be documents that were given by

2 the attorney general's office to my attorney. They are

3 documents that I worked on or my office produced.

4 Also, they were copies of my occupational tax forms,

5 client security fund forms, my good standing

6 certificate from the state of Connecticut and I think

7 that's about it.

8 Q Okay. When did you review these documents in

9 preparation for your deposition?

10 A Over the course of the last several days.

11 Q Okay. And last several days is somewhat

12 subjective. How many days are you talking about?

13 A Friday, Saturday, Sunday, Monday and

14 Tuesday.

15 Q Great. And do you recall how much time you

16 spent reviewing those documents?

17 A I couldn't tell you precisely.

18 Q Okay. How about estimating?

19 A Several hours.

20 Q Okay. Again, several is somewhat subjective.

21 Is that more than three?

22 A Probably.

23 Q More than ten? How many hours would it be

24 then?

25 MR. HORTON: Did you say less than

Brandon Smith Reporting

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1 ten.

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