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From a December 16, 1976, management bulletin by L. S. Shoen, founder of U-Haul and company chairman from 1945 to 1986. The document was obtained by the Los Angeles Times, which last year published a series of articles that found that U-Haul had lost, repaired, or discarded truck and trailer parts sought by injured customers pursuing claims of negligence.

Most of us are at some time compelled to testify by giving a deposition. We are required by law to tell the truth, the whole truth, and nothing but the truth. We are not, however, required to be blabbermouths. Here is what I learned during a recent deposition:

  • That I was in fact a “dumb shit.” By this I mean ignorant as to the accurate answers to most of the questions. After forty-eight hours the memory drops off to approximately 10 percent of what we originally saw or heard. So the first rule is to realize that you are a dumb shit and be glad that you are.

  • The truth is that you are ignorant. Don’t be embarrassed about this. Most of us know only a few things very well and on all other matters we are uninformed. Admit you are ignorant and join the club.

  • Answer the question asked, not the one the opposition’s “hired gun” attorney should have asked. If he asks a stupid question, answer the stupid question.

  • Never tell the hired gun that someone else has a bulletin, letter, memorandum, or document of any kind. You cannot possibly know this to be true, because the other person may have thrown it out since you last saw it. If you never saw it, then you did not know of its existence and cannot testify about your own knowledge. Don’t ever talk about a document unless you have the document in front of your eyes.

  • Never forget that the opposing attorney is a hired gun. His smiles and good manners are a mask to cover his brutal and vicious goal of your destruction. He is paid to destroy you. Never relax in his presence. View him as the mercenary assassin that he is.

  • Tell the truth. Be serious and sincere, and above all be truthful. Here is the rub: we normally blabber about subjects that we truly do not know about. Your careless statements are the buckshot that the hired gun will later use to gutshoot you at the trial.

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June 2008

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