🔊 Pre Deposition debate w/ ORDOJ
Tracy White: [00:00:00] Looks like, I think we're all here.
Anne Duffey: Okay. All right, did you wanna go back on the record, Mr. Isaac?
Logan M Isaac: Yeah, I'm ready.
Anne Duffey: O- Okay, back on the record.
Logan M Isaac: Uh, Ms. Perry, earlier you said you needed a break because your dog was about to bark. Is your dog in the room with you?
Renee Perry: No.
Logan M Isaac: Is there any other reason you might have asked for a break?
Renee Perry: Not beyond that moment.
Logan M Isaac: Can you think of any other reason that you think you may need a break?
Renee Perry: Uh, my knee and hip will hurt me, but we've been taking regular breaks, so that has been a non-issue.
Logan M Isaac: Uh, I'm not sure that we can do that if we wanna try and finish this up, so I think that we should just go through and try and get it done as quickly as possible without breaks.
Does anybody object?
Tracy White: Yes, I object. I need breaks every hour or so, just from the nature of life. So we'll have to press on.
Logan M Isaac: What do you mean press on?
Tracy White: I mean, we will go ahead and we just... But we do have to take breaks. I mean, you can... Y- I know you had set your [00:01:00] 45-minute time, which is fine. If we don't wanna do it every 45 minutes, that's fine, but from time to time, I just have to take a break for, to walk around, go to the restroom, whatever, you know, that kinda thing.
So, um, so if you, if you don't wanna do it yourself every now and then, I'll just say, "We need to take a break now." That's fine.
Logan M Isaac: Okay. Is 45 minutes too much time?
Tracy White: N- no, it's fine, or less than, or less than, or, sorry, or more than that is fine too. I just, if you're gonna think that we're just gonna do the whole rest of the afternoon with no breaks, that's not gonna work for my, my body.
Logan M Isaac: Well, you seem to have a different understanding of what rules mean. Earlier you said on the record that there are no rules, and I'm of the, uh, understanding that if it's not written down, it's not a rule, it's an expectation. And the state and its clients have asserted expectations over and above the rules.
Mm-hmm. So I need to make sure that you and I are on the same page, that you do not continue to believe that you can assert privilege that you don't have over this proceeding.
Tracy White: Well, I can take breaks as [00:02:00] needed. That's the, that's how it is. And if you think that you can be like, "Well, you just don't ever get to go to the restroom," or have no breaks in the entire afternoon, that's unreasonable and, and not gonna happen, so.
Logan M Isaac: Did you hear me say that? That you could not take any breaks ever at any time?
Tracy White: Yeah, you just now said why don't we press on and not have a, have breaks.
Logan M Isaac: So I didn't say that.
Tracy White: I thought that's what
Logan M Isaac: you said. You put words into my mouth. That's called a straw man argument. It's a logical fallacy.
Tracy White: That's
Logan M Isaac: what I thought you said.
Tracy White: So I've asked you before- I'm sorry if I misunderstood you.
Anne Duffey: Guys, let's... Sorry. I need one at a time, and you need to talk slower, please.
Tracy White: Okay.
Logan M Isaac: Ms. White, I'm gonna ask you again on the record to stop interrupting me. I know it's hard, but I've extended you that privilege or that, uh... I've ex- extended you that courtesy, and I expect you to return it.
This is a proportional proceeding. I am counsel for myself, whether you like it, uh, or not, or whether I like it or not. I did not say you cannot take breaks. If you're going to- So- ... cite some reason, it has to be on the record, and it has to be supported by actual facts, not feelings. [00:03:00] Because as you
Tracy White: just see- Let's just go on and see how it goes.
And I'm, you know, so let's just, let's just go on and, and do our best.
Logan M Isaac: Ms. White, if you can't, if you can't refrain from interrupting me, I'm going to have to ask somebody else's intervention, because I literally was just saying that and you continue to interrupt me.
Tracy White: Why don't we just move on and get the deposition done?
Logan M Isaac: Yeah. That's, that's how I led out. As soon as we started, that's exactly what I said, and that wasn't enough for you.
Tracy White: Good. Let's just ask, ask your question. Here we go.
Logan M Isaac: Okay. Yeah. Again, I'll state for the record, you are not in charge of this deposition. Okay?
Tracy White: I have a right to defend my client, and that's what I'm doing, so let us, let us move on.
Logan M Isaac: Rights are not all-inclusive. They're not absolute. As we will see in this case in particular, you do not have a right to your feelings. If you think that I've violated some right, by all means, speak up, but I have rights too, and your rights or your perception of your rights do not override mine. Do you understand?
Tracy White: I hear what you are saying.
Logan M Isaac: Okay, good. I'm glad we're on the same page.
Tracy White: Well, I don't know that we are on the [00:04:00] same page, but I have heard what you said.
Logan M Isaac: Do you feel like you always have to have the last word?
Tracy White: Nope.
Logan M Isaac: Okay, I'm gonna proceed.
Tracy White: Good.
Logan M Isaac: A- anything else, Mrs. White?
Tracy White: Nope
Logan M Isaac: Okay, thank you. I'm gonna proceed. I'm gonna expect that you not speak up while I'm asking a question.
Tracy White: Well, I will speak up as needed to defend my client
Logan M Isaac: That was kind of implied. Are, are you done?
Tracy White: Yeah, no, you said I shouldn't interrupt you, but if I have to interrupt you to defend my client, that's what I'm gonna do.
Logan M Isaac: You think that that wasn't implied in what I said?
Tracy White: Yes.
Logan M Isaac: I think that's unreasonable. I'm gonna continue. If you interrupt me, I'm going to seek sanctions.
Tracy White: Do what you need to do.
Logan M Isaac: Okay. Would you like to follow up everything I say with something, or can I proceed and just proceed? [00:05:00] Okay.
