An excellent question.
One those who support JW have come to understand a long time ago.
Which is why we support JW, eh?
You really ought to go over to ChaseR's thread & collect yourself some names; then simply ask them, ff.
~Assuming they're willing to knock off the obfuscating, & give ya a straight answer.
GO LARRY. Just do it. And get your deposition questions lined up carefully. Don't get sidetracked this time in a flurry of words that lead to nowhere and please, oh please Larry, demand direct answers. Do not let ONE ANSWER go the way of the professional spinners you will be dealing with....I am going to pray for ya. Lindsey and Mills are very gruesome people. Willing to lie to win. And willing to humiliate and obfuscate with glee.
I am going to pray that God grants you the wisdom to ask the questions that will lead to real discovery. As well as the wisdom to immediately reflect upon their answers and ferret out exactly what has been said, enabling you to zero in, big time.
No replays of the likes of Harold Ickes threatening to defacate on your rug, or George Stephanopoulis's arrogant and defiant non-responses, culminating in walking out. Get it right, Larry.
And if there is someone in your office who is better in the deposing dept-let us know so that we can pray for this person, too. Go get um. You have worked hard for the right to depose these creeps-make the most of it....make up sweat. You must be prepared, alert, relaxed, intent and extremely direct. The effort to intimidate and humilate will be no less than Ickes or Stephanopoulis, but there will be more support. You are exposing a crime done with the direct knowledge of the top dogs-get your questions down and simple, hard and fast, and take no prisoners. Let them hang themselves.