{"id":249535,"date":"2025-01-24T10:00:25","date_gmt":"2025-01-24T10:00:25","guid":{"rendered":"https:\/\/dominiclevent.com\/blog\/?p=249535"},"modified":"2025-01-24T10:00:25","modified_gmt":"2025-01-24T10:00:25","slug":"a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation","status":"publish","type":"post","link":"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/","title":{"rendered":"A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation"},"content":{"rendered":"\n<div>\n<div class=\"break_large\">\n<p><span style=\"font-weight: 400;\">Most of us aren\u2019t born with a powerful courtroom presence and a reputation for extracting crucial information in tense depositions. But we can learn.\u00a0<\/span><\/p>\n<p><span style=\"font-weight: 400;\">Guest Tara-Jane Flynn has been called a \u201cPrincess Warrior\u201d and \u201cThe Deposition Queen\u201d for her tough, compelling courtroom manner. But the veteran California personal injury litigator says she started out as a shy girl too overwhelmed to give a classroom speech in school.<\/span><\/p>\n<p><span style=\"font-weight: 400;\">She taught herself to be strong and to be the strength her clients need. She got involved in theater and public speaking. She guest hosted podcasts. And she developed a strong social media presence. You can, too.\u00a0<\/span><\/p>\n<p><span style=\"font-weight: 400;\">In this episode, you\u2019ll hear valuable tips for winning depositions, learning how to leverage social media, and being the lawyer your client needs to believe in from a Los Angeles attorney at home battling for 8-figure verdicts. Get ready to be inspired.\u00a0<\/span><\/p>\n<p><span style=\"font-weight: 400;\">Questions or ideas about solo and small practices? Drop us a line at <\/span><a href=\"http:\/\/legaltalknetwork.com\/cdn-cgi\/l\/email-protection#4709223014282b28072b2220262b33262b2c2922333028352c6924282a\"><span style=\"font-weight: 400;\"><span class=\"__cf_email__\" data-cfemail=\"f3bd9684a09c9f9cb39f9694929f87929f989d9687849c8198dd909c9e\">[email\u00a0protected]<\/span><\/span><\/a><span style=\"font-weight: 400;\">\u00a0\u00a0<\/span><\/p>\n<p><b>Topics:<\/b><\/p>\n<ul>\n<li style=\"font-weight: 400;\" aria-level=\"1\"><span style=\"font-weight: 400;\">Overcoming shyness to become a force of nature in the courtroom doesn\u2019t always come naturally. Learn what you can do intentionally to build your presence and your confidence.<\/span><span style=\"font-weight: 400;\"><br \/>\n<\/span><span style=\"font-weight: 400;\">\u00a0\u00a0<\/span><\/li>\n<li style=\"font-weight: 400;\" aria-level=\"1\"><span style=\"font-weight: 400;\">Social media? It\u2019s not as hard as you think. Find an attorney with a social media presence you admire and do what they do. How\u2019s that for easy? Really.<\/span><span style=\"font-weight: 400;\"><br \/>\n<\/span><span style=\"font-weight: 400;\">\u00a0\u00a0<\/span><\/li>\n<li style=\"font-weight: 400;\" aria-level=\"1\"><span style=\"font-weight: 400;\">Extracting valuable evidence in a deposition can feel intimidating, but there are things you can do. Hear how to let the deponent talk, ask follow-up questions as simple as why or why not, and prepare, prepare, prepare.<\/span><\/li>\n<\/ul>\n<p>Special thanks to our<br \/>\nsponsors , , , and .<\/p>\n<\/div>\n<h6>Transcript<\/h6>\n<p class=\"p1\">Announcer:<\/p>\n<p class=\"p2\">So if I was starting today as a New Solo, I would entrepreneurial aspect, change the way they\u2019re practicing leader, what it Means to be, make it easy to work with your clients, New approach, new tools, new mindset, New Solo. And it\u2019s making that leap. Making that leap<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Hello everyone, and welcome to another episode of New Solo on Legal Talk Network. I\u2019m Adriana Linares I\u2019m your hostess today, my guest is Tara-Jane Flynn. Tara-Jane, thank you so much for taking the time. I know that you\u2019re impacted by what\u2019s going on in the environment locally, but you seem to be okay for now and I really appreciate you taking the time to do this. So welcome.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Thank you. Happy to be here.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">I\u2019m so glad. So you came to me through a friend of the network. Adam Camras is a friend of yours and he said, Adriana, you\u2019ve got to interview Tara-Jane Flynn. She\u2019s amazing. She\u2019s known as the deposition queen or queen of depositions. I\u2019ll get to that in a minute. And she\u2019s really inspiring and wonderful and you should interview her for your podcast. I said, great. I love having strong, powerful and amazing women on the podcast. So welcome and thanks again for taking the time. I know this probably is not the best day to do it, but I appreciate it. I looked at your bio when we first started talking and see that you are born, raised, schooled, educated, everything is California for you, and I wanted you to just give us a little bit of a background how you got to where you are and specifically I saw in your bio that you did some work in Geneva, Switzerland, in getting your education and your experience and I think that\u2019s really interesting. So do you want to add that to what you\u2019re going to tell us?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yeah, actually I was born in England, but I came here when I was two years old. I immigrated with my parents and we went to Northern California and I got my education at several different public schools, but eventually I ended up going to an all girls school called San Domen. And I think that\u2019s really where everything started for me in terms of getting really serious about my academic career and focused on what kind of life I was going to lead as a professional in the future part of what I did in law school. I went to Berkeley undergrad and then I went to USF law school and that\u2019s where I started working for a non-governmental organization through an internship. And that\u2019s when I went to Geneva and I actually spoke in front of the Human Rights Commission.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Wow. Well given you, well, you must have needed a lot of courage and then furthermore, given you even more courage and definitely boosted what is clearly a very strong personality. One of my favorite things in your bio that I want you to address for us is that it says nicknamed Princess Warrior by a now retired judge for your relentless determination, tenacity, mental agility and courage. God, I love that. Do you mind if I copy and paste that into my bio? Tell us just how you developed this attitude. This, I have a feeling you\u2019re aggressive, but you\u2019re probably not the B word.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yeah, there\u2019s definitely a difference between being aggressive and being the B word. I would say that I grew up in a tough environment where there was some abuse and it wasn\u2019t just against me, it was against other family members getting in a situation like that, I became very aware that it\u2019s very important to expose abusers to step in. A lot of times you can stop the abuse if you speak up and you\u2019re just courageous. And I think having learned that as a young child when I was trying to protect people that were older than me gave me the courage to continue to do that during my career, I would say I\u2019m much more protective of other people than I am of myself, and that\u2019s probably why I became a lawyer,<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">That selflessness is such an important thing to have. Did you take any professional training on speaking, like did you go to Toastmasters, did you do debate class help? Give some advice to listeners who maybe are trying to develop that but dunno how to get those skills. I know a lot of it is innate, right? A lot of it, it\u2019s natural, but then so much can be learned. Do you have any advice that you can give us about that?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p1\">Absolutely. I was a very shy child, very, very nervous inside, always shaking maybe a little bit even hyper inside. And I had a situation in seventh grade, I believe, where I was talking about population control in China. I was giving a speech in class and I stood up in front of everyone and the only part of the speech I was able to say is population control in China. And then I blanked out, I turned red and I sat down and I had complete performance anxiety. I also was having issues with taking tests that year I was having and performance anxiety again, or a teacher worked with me a lot to help me through it. But the biggest thing is during the summer I went to an acting class and in a play. And when I came back the next year, I was a totally different person and my teacher noticed it.<\/p>\n<p class=\"p2\">And so she started recommending that I enter speech contests and I did a speech contest at the school I was at and I won every single category of the speech contest for several schools in the region that had come to compete. I got first place. So then I started competing in speech contests outside of school for Mothers Against Drunk Driving. I did things at the legions of honor and in that way I was able to continue to practice speaking. But I would say the most important thing was taking an acting class. And I\u2019ve continued to do that. I went out on my own, I would say in 2016 and I actually went to the School of Acting by John Ruskin. It\u2019s over in the Santa Monica airport, and I took an acting class for about eight months for about five hours a day, a few days a week. And that really helps.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p1\">Wow, that\u2019s amazing. I will further add that when I had my first job at one of Florida\u2019s largest law firms, I started going to Toastmasters, which I don\u2019t care where you are in this country, actually in this world, there is a Toastmasters group near you. And that was probably one of the best things I ever, ever, ever did for myself insofar as becoming a better public speaker. And by public speaking, it\u2019s not even giving a talk in front of 600 lawyers at a bar association meeting, it\u2019s just being able to carry on conversation at a dinner table with a bunch of strangers that you don\u2019t know. So I would encourage everyone, especially actually, it doesn\u2019t matter what stage or age you\u2019re in, Toastmasters is such an easy way to get better at communicating and it\u2019s so benign. They\u2019re so nice, they\u2019re so helpful. So if you\u2019ve been listening to this show for a long time, I\u2019ve certainly mentioned that in the past, and this is a great opportunity to remind people that things like acting classes, things like Toastmasters, doesn\u2019t mean that you\u2019re going to go out and start doing auditions for being on tv.<\/p>\n<p class=\"p2\">Why not? But it just does give you those skills. Speaking of TV though, Tara-Jane, I wanted to ask you, you mentioned that you had been doing a radio series and that that was helpful to your business and exposure. Can you talk a little bit about that because I\u2019m sure your acting skills that you picked up that gave you that confidence to just also work in a visual way, whether it\u2019s in the Courtroom with your clients, must also have helped you with the radio show.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yes. I was invited to be a co-host a couple of times on Call for Justice, that was a radio show that was set up by a criminal defense attorney. Her name was Melissa. And it was very interesting. We had people call in to the show from all areas and ask questions. I did one of the shows with a spine expert, an orthopedic spine surgeon, and then the other show we did a little bit about female empowerment and ways for females to help themselves in their careers and maybe ways that they have felt stunted in their careers.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">I think that\u2019s amazing. And we have had guests in the past who have talked about both radio promotions, radio commercials, and I have had a guest, Conti Moore, who a few years ago was doing, and I think she still does TV commercials, which sound expensive, but she pretty much let us know they\u2019re not as expensive as you think and they are an excellent source obviously, of referrals and potential clients. So something else for those of us to consider that are starting off the new year with a fresh budget for trying to figure out what to do with all those dollars Tar Jane, the litigation world can be interesting. Of course it can be challenging, it can be stressful. Did you always want to do litigation? Did you start transactional? Did you switch to litigation? And talk to us about what being a fierce warrior in the litigation world is like for you today. And again, some advice on how to do that in a way that doesn\u2019t really affect you emotionally. Because I know litigation, especially personal injury work can be very emotional and how to survive through that.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p1\">Well, one of the tools that I use is consistency in my process that really helps me. I do similar things every day. I work out every day. I meditate every day. I make sure that I\u2019m properly eating every day. I have a green juice, I get seven and a half hours of sleep. These are all very important things to do so that when I show up to work or I show up for a client, I have my full arsenal of all of my abilities ready and waiting to serve them. I think that\u2019s something that\u2019s really important for people to do. A lot of people promote, don\u2019t get sleep work all the time, and I just don\u2019t believe in that. I believe that I\u2019m better on my feet. I would rather sleep than prepare and read something because I\u2019m better on my feet as a litigator when I can think with a fresh mind and I\u2019m not tired.<\/p>\n<p class=\"p2\">So that\u2019s one big thing. Being a litigator sort of came about because I started in asbestos and there\u2019s many defendants in cases that involve asbestos victims. I was on the defense side, it\u2019s a pretty aggressive litigation area, and when you go to the depositions, which are many, there\u2019s usually about 30 to 40 lawyers attending the depositions. And I would go to this court reporting center and I was only in my twenties. I was the youngest person to graduate from my law school. So I started out very young and the attorneys, most of them didn\u2019t want to take the deposition, they didn\u2019t want to take lead. So what they would do is they would put their business cards in a stack and then they would just pull one out of the stack to see who would have to take lead. And I\u2019ve always been a pretty ambitious person, so I just started volunteering in every deposition to take lead, and then I just sort of became the leader of the pack. People started assuming I would take leads. So I was the youngest person not playing solitaire on my computer and I was really into it because I like the spotlight, I like digging, I like finding out information. I think it\u2019s exciting to catch someone in the lie, and that\u2019s sort of how it all started.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Oh, I love that. Another thing I wanted to ask you, just an experience I had with you, you don\u2019t even realize the things that you say that stay stuck in people\u2019s minds, right? You are a very caring attorney, you very much care for your clients. And you told me last night that you have a client that\u2019s going through a tough time and you have to call them and sort of walk them through their day, call me after you\u2019ve walked the dog. Don\u2019t forget to get yourself ready and call me when you\u2019re so obviously a very personal one-on-one approach with your clients. I want you to talk to us about that. But I want you to add an important thing, which is when you and I first started communicating, you said, I always answer my phone, I\u2019ll always answer my phone. So just call me if you need me. And I have a feeling you are being nice to me, but I have a feeling that\u2019s really true with your clients. And so many attorneys never want to answer their phone. They don\u2019t want their clients to have their cell phone. And I totally get that part, but your approach seems to be different. Can you tell us why and why that matters?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yeah. I\u2019m working with people that are hurt and they\u2019re not only hurt, but they\u2019re feeling invalidated by insurance companies. They\u2019re feeling isolated over time. People in the beginning when they get hurt, their family surrounds them, everybody understands that they\u2019re hurt. But as time progresses, that individual still continues to feel chronic pain and at a certain time they stop wanting to tell people about it, they start feeling like a burden. And as a lawyer, I\u2019m the one person that they can lean on and they can tell the truth to without burdening their other family members. And I\u2019m happy to be that person for them. I am a very loving person and also from my own experience, having been in a dark place before, I know how important it is for somebody just to talk to you, just to talk to you and give you a little sliver of hope or to make you feel that you do count in this world and that you\u2019re not invalidated. It can make all the difference.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">That\u2019s really amazing. And I have to say, I\u2019ve been doing this podcast for a long time and that\u2019s not normally how we talk about client and client relationships. And it\u2019s just so refreshing, especially again, right now it\u2019s just a tough time for all of us who have any sort of empathy and sympathy in our hearts. So I think that\u2019s amazing. It sounds like you\u2019re the kind of lawyer I would want to hire. Was that an important part in your development and did you realize at the time that it would be, or were you just like, I got this tough girl, I\u2019ll do this.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">No, actually, like I said before, I was pretty shy person. I\u2019m still a shy person, but what I\u2019ve learned, it\u2019s a fake it till you make it. So I sort of push myself into things that are scary because once I do it, I realize it\u2019s not as scary as I thought. I think that\u2019s very important for people. And the more you do that, the more you gain confidence that if you take a risk, it\u2019s going to work out for you. And you also get a lot of practice doing it. You get a better reputation when you take charge. People look at you as a leader. And since I picked this profession, I knew that the most important thing was to build people\u2019s trust in me, to get people to believe that I have a lot of credibility and that I have a lot of balls, like you say,<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">And so much courage. Did you ever worry you would fail?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Oh, of course. I worry all the time. I worried this morning before this podcast. I have an innate sense of wanting to be perfect at the things that I do. And it doesn\u2019t mean that the product has to be perfect, but I want to make sure that I\u2019m following some of the rules that I learned in a very interesting book called The Four Agreements. I always want to do my best, and that\u2019s one of the rules in it. I always want to do my best. Be impeccable with your word, don\u2019t assume anything and don\u2019t take things personally. So I try to go through those ideas before I do something that I\u2019m very nervous to do. And also it\u2019s important to be really kind to yourself, to your inner child and sort of self-soothe and just say, you know what, if I just do my best, that\u2019s all I can do and I love myself and it\u2019s going to be okay.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">That\u2019s very good advice. I say to people all the time, be kind to your mind because we really are so mean to ourselves. Sometimes you have a lot of methodology that is mental and clearly spiritual and how it affects your spirit, which clearly comes through in how you do your work and how you help your clients. And I think that\u2019s amazing.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I\u2019ve always believe even with the things that are going on right now in Los Angeles, there\u2019s darkness in the world, but there\u2019s also light. And where there\u2019s light, there can be no darkness. And I really, really believe in that. So I always try to make sure that I\u2019m turning the light on inside so that no matter what I\u2019m doing, I always feel like at least I\u2019m combating any kind of negativity that I might face in the world because there is going to be negativity out there. There\u2019s no way to avoid it. But always looking for the silver lining, leaning into things, thinking about what is the opportunity that\u2019s being presented to me right now with this obstacle? And when you start living life that way, things start opening up for you.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Great advice. We\u2019re going to take a quick break, listen to some messages from some sponsors. When we come back, I\u2019m going to ask you about your social media and marketing that you do. That is also very impressive. We\u2019ll be right back. Alright, we\u2019re back with Tara-Jane Flynn. She\u2019s a litigation attorney based in Los Angeles, known as the Deposition Queen. We\u2019re going to get to that in segment number three, but I wanted to ask you about social media. All everybody\u2019s talking about now is ai and I think we\u2019re all a little tired of hearing of AI for the past year, and I want to bring it back to one of the basics when it comes to marketing, and that is social media, which of course for some of us is still scary, hard to find the time, but it\u2019s important to you and you do a lot of it. So can you talk to our attorneys or listeners about social media, how you do it, where you find the time, do you really get clients from it because that\u2019s really what they want to know?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I get a lot of leads from it, but not necessarily clients, but I do have a lot of people that reach out that<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Yeah, that\u2019s an important distinction.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yes.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">And<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Even after I don\u2019t take their case, we continue to talk. We sort of become Instagram acquaintance friends, so it really helps me reach out to a lot of different people. People reach out to me. A lot of attorneys are looking at my Instagram that are younger attorneys getting some sort of quick tip or trick of the trade. I like recording it for them because I feel like there are so many things that you can learn quickly that you don\u2019t have to go through all that strenuous trying to figure it out for yourself. I can just tell you, I can just give you that trick or tip that I\u2019ve learned because one thing I\u2019ve always done in my career is I\u2019ve worked around really excellent lawyers and I always copied something from each lawyer that I worked around and then I would make it part of my own sort of in my toolbox. Maybe I would then refine it as I got older and I got more experienced, but I always picked up something from another attorney and I think that\u2019s something that I\u2019d like other attorneys to be able to do for me.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">I think that\u2019s a great tip. Literally copy paste. Do you see something that\u2019s impressive or helpful or effective copy? Just do you spend a lot of time creating those social media posts because I think that\u2019s where a lot of people have paralysis is it won\u2019t be perfect copy. How do I edit? But I think yours are pretty not edited and they\u2019re pretty quick. And maybe you have the attitude I have about social, which is these things don\u2019t last very long anyway. It doesn\u2019t have to be perfect. Just get the information out there. Tell us a little bit about that.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">So a lot of times I\u2019ll just be working and I am aggressive litigator, so I do file motions and I\u2019m constantly trying to figure out a strategy to keep my case in front of the defense attorney be a thorn in their side, so they want to get rid of me more than they want to get rid of the case. And so that\u2019s a tip right there. Yeah, exactly. Yeah, be a thorn in their side. So when I write a motion and I am dealing with an issue, then I think about that. And so I\u2019ll just write then and there at my desk record some sort of tip one sort of little tidbit about what I just did. And usually it takes me, I would say, anywhere between eight and 15 minutes to do<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">It. That\u2019s such good advice because what happens to all of us is that would make a great social media tip. I\u2019ll do it later. And then you never do it or you actually don\u2019t remember what it was. Because as I keep saying to people, my brain storage is full, there\u2019s no more room here. I\u2019d like to get some network attached storage device for my brain. There\u2019s no memory left here. So I think that\u2019s another great tip is if you\u2019re going to start, just start record these small tips, bits, thoughts. You don\u2019t have to edit them. They don\u2019t need background music, they don\u2019t need an introduction. You don\u2019t need a bunch of text on there, just get it out there. You mentioned Instagram. Are you only Instagram or do you also do any of the other platforms?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I just have Instagram and LinkedIn. That\u2019s it. I haven\u2019t tapped into Facebook in a long time. And so yeah, those are the two I use.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">When it comes to LinkedIn, do you do a lot on LinkedIn or are you active on LinkedIn or just use it as a place to have a bio and a place to find you?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I don\u2019t really love LinkedIn. I sort of use it to keep connections with people that I\u2019ve worked with a long time ago. Once in a while I\u2019ll go on it, but I don\u2019t really like the format of LinkedIn. It\u2019s just too much information. It\u2019s constantly posting somebody else\u2019s post of something and I get a little bit overwhelmed when I\u2019m on it, but I do love Instagram.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Any other tips on networking and marketing? I mean, clearly you\u2019re very successful and you get on the community. It sounds like you volunteer a lot. You just get out there. And I think that\u2019s another thing that I cannot ever stress enough. Every successful attorney I have ever had on the show or I have talked to in my 25 years of doing this just says networking, networking, networking. But yet every young attorney that I meet says, I got to build a website. I\u2019ve got to start putting ads on Google networking. They just think it\u2019s not going to work. But yet again, sage, after sage wise person after wise person tells us it\u2019s networking. Do you agree?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I think there\u2019s different ways to network. My networking sort of works after a long time. I think I\u2019m more authentic in my networking. I just try to be there for people. So even on Instagram, I see something going on in somebody\u2019s life. I\u2019ll DM them even if I don\u2019t know them, just sort of be there for them, be a beacon of hope if they\u2019re going through a hard time or support them if they\u2019re just starting a new business and they\u2019re nervous. And I get a lot of people that reach back out to me. Just the other day, a female attorney reached out to me on Instagram, asked me for my phone number and asked me if she could run a couple cases by me. And I ended up calling her back after work and we talked for about two hours. I was happy to give her tips and help her work through some of the medical issues that she had in her case, but really being there for her and showing people that we can help each other without getting something in return. Because what I get in return in that situation is I know that I\u2019m helping another person. We\u2019re creating and building a relationship that could last for years.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">It\u2019s true. And I\u2019m like that too. I give away a lot of time. I give away a lot of emotion and I never find it a waste of my time.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I actually thrive off of it. I think I would\u2019ve been a really good teacher. So I love mentoring and I love teaching. I love sharing things that I\u2019ve learned. I just have an ocean of knowledge and I just want to let it flow everywhere.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">I think I know what you mean. Alright, we\u2019re going to take another break. Our last one, we\u2019ll be right back. We\u2019re going to talk about depositions, how to master depositions. Well, I mean we can\u2019t really do everything in a short time period, but we\u2019re going to do our best. We\u2019ll be right back. All right. I\u2019m back with Tara-Jane Flynn, the princess warrior and the queen of depositions. I feel like you should have a documentary TV show of some sort, Tara-Jane, where you just save the world from everything that\u2019s wrong. But I wanted to ask you about depositions now as you have great experience with them, you have this ocean of knowledge that you want to share. And I don\u2019t even know where to start really, but give me a place to start when it comes to taking better depositions or even listening to depositions, which I think is something maybe we don\u2019t hear about that often. You\u2019re listening and now you\u2019re processing how you\u2019re going to come back into the conversation. So just start somewhere so we have a place to start.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p1\">Okay. Well, you have to remember that juries are not lawyers most of the time. Usually lawyers get bounced from a jury. So you\u2019re talking to people that don\u2019t understand how the law works. And I think I approach things with sort of a childlike mind. I look at everything with a fresh mind and I forget all of my years of experience. And what I try to do in depositions is I approach things with a practical and common sense attitude. I use people\u2019s words against them, and I find their words in several different ways. One, what they just said to me, obviously I like to ask the question why if somebody didn\u2019t do something, I ask them why not? Or I ask them to expand on something that they just said. A lot of times you\u2019ll find that people during depositions, they get defensive and they get arrogant.<\/p>\n<p class=\"p2\">And especially if you\u2019re dealing with a corporate representative and they\u2019ll start fighting back at you. And then that\u2019s the perfect situation to get in because they talk too much. And I usually write down notes as I am speaking. I\u2019m able to do both at the same time, and then I\u2019ll go through some of the extra things that they just told me that maybe have nothing to do with the case, and I\u2019ll start pressuring them on those points and making them eat their words. So it starts creating an environment where they feel like I\u2019m out leveraging them and I\u2019m able to put them in a place where now I\u2019m running things in the deposition. When I say I use people\u2019s words against them, another thing I do is I take their verified discovery responses and I look through it very carefully before a deposition. I get them to confirm that they have verified all those responses under penalty of perjury because there\u2019s a lot of lawyers out there, especially defense lawyers that are writing answers for their clients and not running those answers really by their clients. And their clients are verifying discovery. So oftentimes you\u2019ll find that the client, the defendant, will sort of get trapped into a box where a defense attorney has come up with an idea that this is a good strategy to go with, that might include a lie that the defendant is not able to keep up with.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">How did you learn all this practice?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I dealt with an individual growing up that constantly interrogated me. So I guess I learned some skills that way. The school of hard knocks. Yeah, the school of hard knocks. I was able to think on my feet very quickly just through practice and realizing that it works. Another important thing for depositions is to break things down into steps. I like to ask people, what were you wearing the night before? What did you eat for breakfast? What did you do next? And I break it down into such small steps that I don\u2019t even realize sometimes where I\u2019m headed, but the conclusion that the defendant or the deponent that I\u2019m taking the deposition of wants me to get to might not be there when we get to the end of the path when we\u2019ve taken all those little steps.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">So you\u2019re sort of impromptuly, is that a word? What\u2019s the word I\u2019m looking for?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Spontaneously?<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Yeah, I guess spontaneously is better. Okay. So you\u2019ve got a plan, but it involves or allows for a lot of spontaneity, which I think a lot of attorneys don\u2019t like to have or think about because they\u2019re so procedural, they\u2019re so methodical, which is interesting because you\u2019re very methodical in other ways. But it sounds like in this case you do have a lot of play in the wheel for spontaneity and it works out for you.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yep, that\u2019s true. And I think I got that as I was working as a criminal prosecutor, as a city attorney in Los Angeles, and during that time I did it voluntarily. And during that time, you get the file about 45 minutes before the trial starts, and so you can\u2019t really prepare very, very well for that. So you really do have to rely on the spontaneity of asking questions at trial that you might not know the answers to. So that helps sort of burst the bubble of thinking that I always needed to know exactly what I was going to ask at a deposition. But on the other side, even though I\u2019ve done several thousand depositions in my life, every time I take a deposition, I write an outline and I over prepare. I know every single word in the file, including the medical records. I just am an over preparer because I always think that I\u2019m going to blank out. I still have that nervousness that I had when I was a kid and I found ways to cope with it by always being over-prepared.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">How many cases on average are you carrying?<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">It depends. I\u2019ve carried up until 70 cases and I\u2019ve carried as little as eight to 10 cases. The cases I\u2019m working on now are all seven and eight figure cases.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Wow. And you take that much time, even though you said you get enough sleep and do your routines all the time. And are that prepared? That\u2019s impressive.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yeah. Well, when I was doing more cases, that\u2019s when I was younger and I did wake up a lot earlier when I was younger. I was waking up at five in the morning to work out. I was having to drive down to downtown Los Angeles. I mean, things were just different back then, but also now that I am dictating strategy, I am in charge of all the cases. I\u2019m able to make my own decisions, plus I have a lot of experience. It doesn\u2019t take me eight hours to write emotion anymore. Sometimes it just takes me an hour and a half. I\u2019m able to do things without really relying on resources, just do things from my own mind because of all that practice and experience.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Right. Well, for sure, experience is definitely a huge factor in your success, in your abilities today. I wanted to ask you, are you using AI in any way to help you prepare for depositions or write motions, or are you just using AI in general? I know it\u2019s been a hot topic for the past year or any sort of technology that you want to share.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">I use, there\u2019s something called the Wayback Machine. I use that sort of to see what type of statements corporations have said on their websites in the past that maybe they\u2019re changing. For instance, like a defendant like Lyft, they may have advertised certain things to the public at one point in time and then realized because there were lawsuits that they should change their tune. And so it really is helpful because their party admissions to go back on the way back machine and look at something that they said on their website in a snapshot that that machine has captured and use those words against them. Just like I explained earlier.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Here it comes full circle. For those of you listening, if you haven\u2019t heard of the way back machine, it\u2019s actually been around for tens of years and it\u2019s a service that captures snapshots of websites over time. Sometimes you\u2019ll go, let\u2019s say you want to look at Coca-Cola\u2019s website. It\u2019ll have a snapshot every single day for the past 20 years. Or you might go to the Coca-Cola website and it might only have a snapshot once every five months. So it kind of depends. It\u2019s not a perfect site, but it can certainly be very helpful. And I think it\u2019s really interesting that one of the places that you go in your research, I mean, that\u2019s just diligence. It\u2019s amazing.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Another thing is I take a lot of zoom depots because they\u2019re remote depots since covid, and I like to use the split screen effect and where I show exhibits at the same time that the deponent is speaking and they\u2019re videotaped so they can be used at trial. And so the deponent will be saying it was a fender bender, and on the other side of the screen you see a car completely split in half smashed all the airbags deployed. Those type of things are very effective.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Yes, that sounds very effective and so obvious, right? Yes. This seems obvious, but I can\u2019t imagine that there is not a listener somewhere going, oh, that\u2019s a very good idea. But sometimes the best ideas are the ones that are so obvious. We don\u2019t even think of them until somebody says it, and then you go, copy paste. I\u2019m going to copy paste that<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Idea. And that\u2019s why you have to keep that childlike mentality that every time you approach something, you have to approach it with fresh eyes because then you remember to do the obvious things.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Well, and speaking as a person who is not an attorney but talks to attorneys all day, it\u2019s amazing how many times, just because I work in legal, they\u2019re talking to me as if I am an expert, a paralegal or an attorney of some sort, and I have to remind them. I go, whoa, wait a minute. Talk to me like I\u2019m four because I don\u2019t actually know what you\u2019re saying. And I think a lot of times attorneys, not just me, I\u2019m not a great example because I live in this world, but that\u2019s how they talk to their clients. And we have to be reminded that especially in a world like yours, you really are talking sometimes to the average person, an average citizen who has no exposure to any sort of legal experience. So again, I think that\u2019s really great advice.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Your clients are scared too. They don\u2019t know what\u2019s going on. They don\u2019t understand the process. If a trial gets continued, they\u2019re upset. They think their rights have been stripped. And that\u2019s why it\u2019s really important to keep in constant contact with your clients so that you build that trust and you can explain things to them along the way, not only to protect yourself, but to make that person feel more comfortable when they\u2019re going through the process, because it\u2019s very scary for them.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Yeah. Well, Tara-Jane, I cannot thank you enough for your time, and I do want to make sure, and also thank you for your honesty, and you expressed some things that were clearly very personal. You\u2019re not afraid to talk about it. It\u2019s part of your experience that has clearly made you such an excellent attorney and such a good person. And I think that\u2019s also just so refreshing to hear. We hide a lot as humans, and it\u2019s just really nice. So thank you.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yeah, thank you. If anyone wants to follow me, my Instagram handle is at Personal Injury California.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">That\u2019s right.<\/p>\n<p class=\"p1\">Tara-Jane Flynn:<\/p>\n<p class=\"p2\">Yeah. And I think I\u2019m going to start actually teaching courses. I\u2019m going to start putting together courses for attorneys so that they can learn some of those tips that I have on my social media so that they can start implementing them into their own litigation practice.<\/p>\n<p class=\"p1\">Adriana Linares:<\/p>\n<p class=\"p2\">Well, you absolutely should. It\u2019s so helpful. It\u2019s so sought after attorneys, especially young attorneys, but even older attorneys who might be switching career paths or switching disciplines are hungry for that kind of information. I think. Well, when you decide to do that, you make sure and let me know, you have now told us how people can find friend or follow you. It sounds like Instagram is the best way to do that. And I want to thank you again so much for your time and sharing all this information with us, and hope that you and the rest of our friends, family, and circles and networks and everyone else in California gets through all this. Next month we\u2019ll record a new episode. This will be behind us, and hopefully we\u2019ll all have fresh eyes and bright eyes on better days. Thank you for having me. It was my pleasure. Thanks everyone for listening to another episode of New Solo on Legal Talk Network. Hope to see you next month. I\u2019ve<\/p>\n<p class=\"p1\">Announcer:<\/p>\n<p class=\"p1\">Been running from nine to five. My all this time won\u2019t let anyone me show. I was thinking this was the way to go and you put up,<\/p>\n<p><a class=\"js_episode_notes_btn episode_notes_btn btn btn_gray text_small hidden\" href=\"#\">Continue Reading<\/a><\/p>\n<\/div>\n\n<p><a href=\"https:\/\/legaltalknetwork.com\/podcasts\/new-solo\/2025\/01\/a-princess-warriors-tips-for-overcoming-fear-and-standing-tall\/\">Source link <\/a><br \/>\n<a href=\"https:\/\/www.dominiclevent.com\/\" target=\"_blank\" rel=\"noopener\"><img loading=\"lazy\" decoding=\"async\" class=\"aligncenter size-medium wp-image-19471\" src=\"https:\/\/dominiclevent.com\/blog\/wp-content\/uploads\/2017\/11\/litigation-300x225.jpg\" alt=\"\" width=\"400\" height=\"350\" \/><\/a><\/p>\n<p><center><iframe loading=\"lazy\" src=\"https:\/\/www.google.com\/maps\/d\/u\/1\/embed?mid=1w4tN9mf5kVdBXUXTq2KvwE23NmpUzEna\" width=\"640\" height=\"480\"><\/iframe><\/center>&nbsp;<\/p>\n<p><center><iframe loading=\"lazy\" style=\"border: 0px #ffffff none;\" src=\"https:\/\/calendar.google.com\/calendar\/embed?src=sc635csnrm8h9s9lq0cad6vkss@group.calendar.google.com\" name=\"myiFrame\" width=\"600px\" height=\"3px\" frameborder=\"1\" marginwidth=\"0px\" marginheight=\"0px\" scrolling=\"no\" allowfullscreen=\"allowfullscreen\"><\/iframe><\/center>&nbsp;<\/p>\n<p><center><\/center><\/p>\n<div>\n<div><img decoding=\"async\" src=\"http:\/\/www.dominiclevent.com\/wp-content\/uploads\/2018\/06\/Business_Solicitors_London.jpg\" width=\"600\" \/><\/div>\n<p>&nbsp;<\/p>\n<div>Dominic Levent Solicitors<\/div>\n<div>Email: Enquiries@dominiclevent.com<\/div>\n<div>Phone: 020 8347 6640<\/div>\n<div>Url: https:\/\/www.dominiclevent.com<\/div>\n<div style=\"display: none;\">cash, check, credit card, invoice<\/div>\n<p>&nbsp;<\/p>\n<div><\/div>\n<div>\n<div>1345 High Rd<\/div>\n<div>London, London N20 9HR<\/div>\n<\/div>\n<\/div>\n<p>&nbsp;<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Most of us aren\u2019t born with a powerful courtroom presence and a reputation for extracting crucial information in tense depositions. But we can learn.\u00a0 Guest Tara-Jane Flynn has been called a \u201cPrincess Warrior\u201d and \u201cThe Deposition Queen\u201d for her tough, compelling courtroom manner. But the veteran California personal injury litigator says she started out as &hellip; <\/p>\n<p class=\"link-more\"><a href=\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/\" class=\"more-link\">Continue reading<span class=\"screen-reader-text\"> &#8220;A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation&#8221;<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[5],"tags":[],"class_list":["post-249535","post","type-post","status-publish","format-standard","hentry","category-news1","entry"],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v26.4 - https:\/\/yoast.com\/wordpress\/plugins\/seo\/ -->\n<title>A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation - Dominic Levent Solicitors Blog<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation - Dominic Levent Solicitors Blog\" \/>\n<meta property=\"og:description\" content=\"Most of us aren\u2019t born with a powerful courtroom presence and a reputation for extracting crucial information in tense depositions. But we can learn.\u00a0 Guest Tara-Jane Flynn has been called a \u201cPrincess Warrior\u201d and \u201cThe Deposition Queen\u201d for her tough, compelling courtroom manner. But the veteran California personal injury litigator says she started out as &hellip; Continue reading &quot;A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation&quot;\" \/>\n<meta property=\"og:url\" content=\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/\" \/>\n<meta property=\"og:site_name\" content=\"Dominic Levent Solicitors Blog\" \/>\n<meta property=\"article:published_time\" content=\"2025-01-24T10:00:25+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/dominiclevent.com\/blog\/wp-content\/uploads\/2017\/11\/litigation-300x225.jpg\" \/>\n<meta name=\"author\" content=\"spainops\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"spainops\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"37 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/\",\"url\":\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/\",\"name\":\"A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation - Dominic Levent Solicitors Blog\",\"isPartOf\":{\"@id\":\"https:\/\/dominiclevent.com\/blog\/#website\"},\"primaryImageOfPage\":{\"@id\":\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/#primaryimage\"},\"image\":{\"@id\":\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/#primaryimage\"},\"thumbnailUrl\":\"https:\/\/dominiclevent.com\/blog\/wp-content\/uploads\/2017\/11\/litigation-300x225.jpg\",\"datePublished\":\"2025-01-24T10:00:25+00:00\",\"author\":{\"@id\":\"https:\/\/dominiclevent.com\/blog\/#\/schema\/person\/bacc79b48921539cd8fc642f86d23254\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/\"]}]},{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/#primaryimage\",\"url\":\"https:\/\/dominiclevent.com\/blog\/wp-content\/uploads\/2017\/11\/litigation-300x225.jpg\",\"contentUrl\":\"https:\/\/dominiclevent.com\/blog\/wp-content\/uploads\/2017\/11\/litigation-300x225.jpg\"},{\"@type\":\"WebSite\",\"@id\":\"https:\/\/dominiclevent.com\/blog\/#website\",\"url\":\"https:\/\/dominiclevent.com\/blog\/\",\"name\":\"Dominic Levent Solicitors Blog\",\"description\":\"\",\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\/\/dominiclevent.com\/blog\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Person\",\"@id\":\"https:\/\/dominiclevent.com\/blog\/#\/schema\/person\/bacc79b48921539cd8fc642f86d23254\",\"name\":\"spainops\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/dominiclevent.com\/blog\/#\/schema\/person\/image\/\",\"url\":\"https:\/\/secure.gravatar.com\/avatar\/6a2648c0ace71d8dde31f2a9e8b370b694f81d70a3ed9ccfb9ec45550a223943?s=96&d=mm&r=g\",\"contentUrl\":\"https:\/\/secure.gravatar.com\/avatar\/6a2648c0ace71d8dde31f2a9e8b370b694f81d70a3ed9ccfb9ec45550a223943?s=96&d=mm&r=g\",\"caption\":\"spainops\"},\"sameAs\":[\"https:\/\/dominiclevent.com\/blog\"],\"url\":\"https:\/\/dominiclevent.com\/blog\/author\/spainops\/\"}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation - Dominic Levent Solicitors Blog","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/dominiclevent.com\/blog\/a-deposition-queens-tips-for-overcoming-fear-and-standing-tall-during-litigation\/","og_locale":"en_US","og_type":"article","og_title":"A Deposition Queen\u2019s Tips for Overcoming Fear and Standing Tall During Litigation - Dominic Levent Solicitors Blog","og_description":"Most of us aren\u2019t born with a powerful courtroom presence and a reputation for extracting crucial information in tense depositions. But we can learn.\u00a0 Guest Tara-Jane Flynn has been called a \u201cPrincess Warrior\u201d and \u201cThe Deposition Queen\u201d for her tough, compelling courtroom manner. 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