If You Know Lawyers, I Need Your Advice

What is the name of your state? FLORIDA

I am the plaintiff against a nationally known Nursing company. We are going to trial in about a month. I, representing myself, tried to schedule a deposition on the main defendant.

I contacted them two days ago, and they said they could not do the depo until 5 business days before the trial. One lawyer is getting married; the other is in a trial.

QUESTION: I want to file a motion to force them to do it earlier, because if anything unexpected comes up, either I will have to pay $200 more to get the depo in time or not get it at all.

The lawyer talks nice and says he'll try to help if he can, but who can trust an opposing lawyer?

QUESTION 2: If I file a motion and get it, can I expect the lawyers to be upset and try to overwhelm me in court with legal intimidation since I am representing myself?

Should they set the depo earlier than 3 weeks from now and a week before the trial or is this "a ploy", so to speak?

PLEASE NEED YOUR THOUGHT?

First, the other attorney is going to "overwhelm you in court with legal intimidation" whether you file a motion or not. The other attorney's job is to represent their client the best way possible.

Since you are representing yourself be prepared for the court to expect you to know all the proper procedures and legal foundations for evidence, objections, document introduction, etc.

You will not get a break just because you are not an attorney.

I suggest you set the deposition and send a letter indicating no continuance will be allowed. Also state that if no one shows up you file a motion to exclude the testimony of that defendant from the trial.

The other attorney will be forced to file a motion to continue the trial thereby giving you more time to get your discovery completed.

Good logic BUT

That defendant that I am going to take the depo on is my best witness as plaintiff. I have indisputable records that will force her to answer the questions that will support if not make my case!

I want to be absolutely sure I get her depo!

Thanks for the suggestions