Posted by Shoshana/AZ on 8/5/12 7:00pm
Msg #429433

A question about a telephonic deposition tomorrow

I have a deposition in the early AM. The client is being asked to present her DL and SS card. I haven't seen the verbiage on the affidavit, but she said it does say SS card. Client went to the SSA office in Phoenix to get a duplicate card. Apparently, they no longer issue cards on the spot. It has to be sent from Baltimore. So, they gave her a letter. I asked the client to ask her attorney if they will accept the letter verifyng her SS# and if so, could she change (and initial) the verbiage on the affidavit to reflect that she presented the letter rather than a card?

Would anybody have handled this differently? If so, how?

Reply by Karla/OR on 8/5/12 9:24pm
Msg #429445

Shoshana~ I can't imagine the SS letter (with government letterhead) being rejected, especially when that was the end result of her efforts to get a replacement SS card for the deposition. Besides, she does carry a valid DL.

Just curious, will both attorneys be at the deposition? Was the opposing attorney the one requesting the deposition, DL, AND SS card???????

I think you did all you could do. If the SS letter IS rejected, will you know before heading to the deposition?

Reply by Shoshana/AZ on 8/5/12 9:34pm
Msg #429446

I don't know much about it right now. The law firm is in FL where she used to live. so, I have to be at her house by 6:45 am for a 10:00 Am (EDT) deposition. I just imagine that she can't swear to having a SS card, if what she has is a letter!
As I stated in the title, this is a telephonic deposition. I just hope that she finds out before I leave the house!

Reply by Karla/OR on 8/6/12 1:50am
Msg #429460

You may not know, but is HER attorney in Florida as well as the opposing attorney?? Hopefully she is not far in case the deposition gets cancelled after you get there.

Wish I could be of help. Good luck tomorrow. Let us know what the outcome is, okay?

Reply by Shoshana/AZ on 8/6/12 7:54am
Msg #429471

I am waiting for the phone call. Time to get dressed I guess!

Reply by Shoshana/AZ on 8/6/12 10:02am
Msg #429479

It turned out to be a BK hearing. They had no problem accepting the letter from the SSA.

Reply by Karla/OR on 8/6/12 2:26pm
Msg #429522

Interesting, so glad it went well in the end! n/m