The Couch

The Couch – The Run-on Client

The Couch is a learning place, not only for its contributors but also for our readers who engage in the ensuing discussions. What do you do when you are the victim of unusual practices or an out of control situation?


You have met them. Sweet looking, polite, state they understand your instructions, the lawyers’ instructions… Then the questions start, and they can’t stop talking!

It doesn’t matter if it is at a trial, deposition, doctor’s consultation. We have all met a chatterbox.

How do we put a stop to that verborrhea?  This is something I am having difficulty with and could really use some guidelines.

Thank you in advance.

– Burning Ears


Please note: Contributions to The Couch should be sent to the Editor and not entered in the comments. We will make sure that all data that might make the parties or case identifiable are removed.


Check out other topics discussed here and here.

Join us in Nashville
2 Comments
  • Gio
    Posted at 17:55h, 11 March Reply

    Oh, yeah. It seems to be a common ailment to deponents. I do not have afinal answer, but I have tried a few things that work with different people.

    Definitely, giving deponents instructions on how to work with the interpreter is crucial. Then, next comes “The Hand”: flat, fingers outstretched and together, like a knife, going from vertical (pointing upwards) to horizontal. If that does not work, I go on the record and ask counsel to instruct the deponent to breathe, to wait until the interpreter is finished. If that doesn’t work, they will have to accommodate my requests for repetition.

  • Karyn Simmons
    Posted at 08:36h, 13 March Reply

    I have found that a hand gesture (the “wait” sign) usually works well to remind clients of both languages to pause. Otherwise, as Gio said, express the problem for the record and then ask for repetitions as needed. Off the record (attorney-client meetings, for instance, or doctors’ offices), you can sometimes switch to simultaneous.

Post A Comment