The deposition was held at 4000 Six Forks Road, Raleigh, North Carolina. Representing defendant, Buckeye Noble, is Michael S. Rothrock, Defense Counsel. Representing the plaintiff, Wild Thing, is William Thurgood Suemall, Defense Counsel. All parties are present. Defendant is sworn is by raising his right paw and giving an affirmation bark.
Suemall: May I call you Buckeye?
Suemall: Okay, MISTER Noble…
Buckeye: No I meant you can’t call me because I am not allowed a cell phone.
Suemall: My God.
Buckeye: Oh no, don’t call me that, call me Buckeye
Suemall: Rothrock, tell your client to stop it!
Rothrock: Stop it
Suemall: On June 9, 2010, were you not a guest at Grove Park Dog Resort in Asheville?
Buckeye: If you call being thrown in the back of the SUV with my two sisters, being driven at 100 miles per hour with no stops by a couple of people who want to do a ‘get-a-way’ and then stuck in a 4×6 room in a dog kennel while they get a $1200 a night suite on the Club Floor a guest, I guess so. I called it being held hostage by leash.
Suemall: And during that visit and during a group social event, did you not meet my client, Wild Thing?
Buckeye: Look, dude, have you ever been in a pet park? You don’t ‘meet’ you jump in the fray and survive!
Suemall: Rothrock! tell your client to stop it!
Rockrock: Stop it!
Buckeye: He gets a bit testy doesn’t he?
Suemall: Oh my God
Buckeye: Look ..it’s okay, just call me Buckeye. I’m not God.
Suemall: Let’s regroup and get to the point. Did you or did you not viciously attack my client and bite Wild Thing on the rear end causing great emotional distress and pain and suffering?
Buckeye: Look, Dude Counsel, you need to back up. That is not how it was.
Suemall: Answer the question
Buckeye: What question?
Suemall: The question I just asked
Rockrock: Buckeye, when the nice man asks you a question just try to answer it very simply. You aren’t having a conversation, okay? Just the facts, man.
Buckeye: Well it takes the fun out of it but okay. What was the question?
Buckeye: Don’t worry I remembered it.
Suemall: Answer the question
Suemall: No you won’t answer the question?
Buckeye: No I didn’t do what you said, you know attack Wild Thing.
Suemall: What do you call running into the park, leaping on top of Wild Thing, and then viciously biting Wild Thing on the rear end?
Buckeye: I can tell you what my dad calls it but I don’t think you want to know.
Buckeye: Look, the truth of the matter is that Wild Thing is a fine looking dog and I, well my Mom says I am high on the gene pool but weak in the upper deck, if you know what I mean. I saw Wild Thing and forgot my gene delivery system was removed and wanted to take advantage of my ability to improve dog-kind, so once I…
Suemall: Look it doesn’t matter why you did it?
Buckeye: Okay, dude, you know there is such a thing as spousal privilege right?
Suemall: What the H….
Buckeye: Anyhow, sitting next to you, your client there, her name is going to be Wild Thing Noble by the time we get to trial , you now, doggie spouse privilege and ..
Suemall: ARRRRRRRRRRRRRRRRGHHHHHHHH ROTHROCK!
Rothrock: Well this is what I call a dog-gone good day!
The deposition was concluded due to the inability of the plaintiff’s counsel to continue.
A special thanks to Mike Rothrock, a Raleigh plaintiff’s attorney, who graciously allowed us to utilize his fine litigation skills and name in handling Buckeye’s deposition. We recognize it is traumatic for him to be on the defense size but it is a “Noble” cause. Of couse, Mr. Suemall is fictitious and bears no resemblance to any of the many fine plaintiff’s lawyers we have met in our journeys. And in fairness…a few defense lawyers as well.