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Gibson’s Bakery says Oberlin College’s scorched earth defense justifies large legal fee award

Gibson’s Bakery says Oberlin College’s scorched earth defense justifies large legal fee award

“For instance, Grandpa Gibson, who is 90 years old, was subjected to five (5) days of questioning lasting nearly nineteen (19) hours.”

The post-verdict fight over legal fees continues in the Gibson’s Bakery v. Oberlin College case.

The jury decided that Gibson’s would get attorney’s fees, but it is up to Judge John Miraldi to determine the amount.

Last week Daniel McGraw reported on the court hearing, and the astounding fact that the lawyers on each side had time into the case equaling just under $5 million. The defense lawyers got paid hourly, the Gibson’s lawyers have the case on a 40% contingent fee, but kept track of their time.

Now we have most of the filings made in connection with the application for legal fees. We don’t have everything, because some filings were made under seal and are not publicly available.

The Application for Legal Fees (pdf.)(full embed at bottom of post) filed by Gibson’s shed light on why the lawyer time into the case was so high. Oberlin College litigated the stuffing out of the case:

Before discussing the specific rates and hours for each attorney, the complexity and magnitude of the litigation must be outlined. This case required five (5) weeks of trial with an additional week dedicated to arguing motions in limine and Daubert challenges. Combined, both parties called thirty-three (33) witnesses during trial with some examinations lasting numerous hours. In addition to actual trial time, discovery and pre-trial issues were complex and contentious, with nearly fifty (50) depositions, hundreds of thousands of pages of discovery exchanged, and numerous discovery and procedural motions filed.

Importantly, a significant portion of Plaintiffs’ fees were expended because of Defendants’ counsel’s actions:

Depositions. Defendants took thirty-two depositions, including nearly the entirety of the Oberlin Police Department. During these depositions, Defendants subjected numerous witnesses to multi-day questioning. For instance, Grandpa Gibson, who is 90 years old, was subjected to five (5) days of questioning lasting nearly nineteen (19) hours. Similarly, Dave was subjected to three (3) days of questioning lasting 20 hours.4

Not even nonparties were spared. Lorna Gibson, Dave’s wife, was subjected to two (2) days of questioning lasting nearly ten (10) hours. Lieutenant Michael McCloskey was subjected to two (2) days of questioning with the vast majority of that questioning coming from Defendants. Local reporter Jason Hawk was likewise subjected to two (2) days of questioning, the vast majority of which was asked by Defendants’ counsel. Store clerk Brent Gingery was questioned for more than seven (7) hours. Even 85-year-old Dr. Roy Ebihara was deposed on multiple days….

Regardless of the actual intent behind Defendants’ tactics throughout this litigation, there can be no doubt that they led to an extraordinary amount of time required of Plaintiffs’ counsel to take this case through trial.

Motion Practice. Defendants also littered the pre-trial docket with numerous unnecessary procedural and discovery motions. By Plaintiffs’ count, Defendants filed seventeen (17) motions. Defendants lost, at least in part, the vast majority of these motions. Additionally, a substantial portion of the documents Defendants produced were withheld for several months due to unnecessary motion practice on the extent of discoverable ESI.

Evidentiary Motions. By Plaintiffs’ count, Defendants filed sixteen (16) motions in limine and Daubert challenges that required a week of hearings and arguments to resolve.

Based on the complexity and length of the case and the actions of Defendants’ counsel, the lodestar amount for the legal services provided by Plaintiffs’ counsel is inherently reasonable.

In sum, the Gibsons’ seek, in addition to the $25 judgment, “attorneys’ fees between $9.5 million and $14.5 million, which is the lodestar amount with a two to three multiplier enhancement, and litigation expenses of$404,139.22.”

Oberlin College’s Opposition (pdf.) and Gibson’s Reply (pdf.)(full embeds at bottom of post) argue over the law, the billing practices and record keeping, and what “reasonable” attorney’s fees means in this context. You can read the arguments at the links and below.

The big takeaway is that this was a case of Oberlin College not seeing the forest for the trees at so many levels.

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Gibson’s Bakery v. Oberlin College – Plaintiff’s Application for Attorney’s Fees and Expenses by Legal Insurrection on Scribd

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Gibson’s Bakery v. Oberlin College – Defense Opposition to Plaintiff’s Application for Attorney’s Fees and… by Legal Insurrection on Scribd

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Gibson’s Bakery v. Oberlin College – Plaintiff’s Reply in Support of Application for Attorney’s Fees and Ex… by Legal Insurrection on Scribd

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Comments

rabid wombat | July 15, 2019 at 9:34 pm

“F” Oberlin and their horse

Cordially

    Wisewerds in reply to rabid wombat. | July 16, 2019 at 2:28 am

    I predict the Judge awards the plaintiffs’ attorneys about 6-7.5 million.

      Observer in reply to Wisewerds. | July 16, 2019 at 10:48 am

      Higher. At least $9 million.

        Tom Servo in reply to Observer. | July 16, 2019 at 11:30 am

        Yup – Oberlin, you played scorched earth, you thought it was smart to go “all in”. So now you pay the piper.

        Wisewerds in reply to Observer. | July 16, 2019 at 2:06 pm

        I don’t think it will be that high.

        Plaintiffs in these situations always ask for more than they really expect to get. The judge knows that.

        And, judges in these situations often play “split the baby.”

        So, I think the judge will go through the Plaintiff’s lawyers time, lop off about 1.0 to 1.5 million or so in “unreasonable” or “unproductive” time, and then double the remainder.

        And if I were the plaintiff’s lawyer, I would be extremely happy if that results in a final award of 6-7.5 million.

        I am not saying that’s how it should work. But that is in fact how it is likely to work.

    C. Lashown in reply to rabid wombat. | July 16, 2019 at 11:53 am

    You might want to re-think that. Their horse has an STD.

This Oberlin trash is of a kind with AOC and her band. Leaving America would be a good idea. They clearly don’t appreciate it here.

Except it doesn’t. The attorneys got their hours in and way more than are reasonable for such a case. On the other hand, Federal Rules allow only 7 hours for a deposition without court permission. Most States have similar rules. What the hell was the judge thinking that allowed this?

    Brave Sir Robbin in reply to puhiawa. | July 15, 2019 at 11:59 pm

    A judge will almost always allow more time for extended deposition and motions. To summarily dismiss such requests invites successful appeal. Also, litigating whether or not such motions and extended depositions should be allowed also costs more time and money in and of itself, so the abusive side has incentive for the judge to not simply allow it.

    As the judge knows this is a strategy to make the costs for the other side untenable, he has to weigh the costs to the other side of trying to reign in the aggressive/abusive side. Either way, counsel gets to pad his bill trying to force out the other side due to costs. Unless the abusive counsel is taken before the state bar, their is really not down side to the tactic if allowed by the client who is willing to pay for it.

      Tom Servo in reply to Brave Sir Robbin. | July 16, 2019 at 11:33 am

      It appears to me that the criticism of the Judge here is for him giving Oberlin’s attorney’s exactly what they asked for.

      It’s looking like he gave them all the rope they wanted to hang themselves with. Now they’re mad, saying “why did you let us have so much rope?”

      I was going to have my own response stating what you did in your second paragraph.
      A “Run the other guys out of money” strategy.
      And if the Gibson’s team had not matched the Oberlin team, step for step, the Oberlin team would have tried to inflict some falsehood or damage that would have been unresolvable, or at least difficult and expensive to resolve, in court.
      Unresolved falsehoods that might have changed the verdict or at least the judgement amount.

        MajorWood in reply to jhn1. | July 17, 2019 at 11:09 am

        This entire case was an unresolve able falsehood, which necessitated taking it to trial. It has provided me with a great template with which to teach my son a whole bunch of essential life lessons on proper behavior, based on Oberlin exhibiting no proper social behavior here and suffering the consequences in spades.

        Oberlin College has become a cautionary tale.

Daubert challenges?
What evidence in the trial required a Daubert challenge?

Abuse of process often figures into penalty awards. Now we will see how impressed the judge is with the antics of Oberlin’s counsel.

Brave Sir Robbin | July 15, 2019 at 11:42 pm

My experience is that abuse of process is rarely penalized. Abuse of process is a tactic applied by one side or the other to drive away the other party due to the costs involved. It is employed by a deep pocketed side against a lessor resourced side.

In this case, Oberlin figured if Gibson’s counsel was not too sure of the case, he would not sink so much time into it since he was on contingency most certainly. That Plaintiff’s counsel kept pace with Oberlin should have been an indication to them that was not heeded, probably because they did not care because it’s also very lucrative to an attorney on an hourly rate.

The strategy is advantageous to the employing counsel because it helps him pad his bill against the deep pocketed client. Basically, Oberlin was taken to the cleaners by their counsel.

Since Oberlin let them go out of control, and since they are sophisticated clients and must have realized what their counsel was doing, they get what they deserve and will end up having to pay out even more to cover Plaintiff’s attorney’s fees and court costs. But hey, it’s not their (Oberlin administrators and defendant’s) money. It’s just some numbers on a some account statements that belongs to Oberlin, not their own personal accounts.

I am not impressed with Oberlin’s representation. This is such a huge and embarrassing loss it has to affect the firm’s reputation.

    “Since Oberlin let them go out of control, and since they are sophisticated clients and must have realized what their counsel was doing…”

    Wouldn’t this argue that the judge may inclined to make up some of the damages lost due to the legal cap by allowing the maximum? Not much you can do to punish the lawyers but if their client was doing the pushing, seems to me that this could be a reason cited in the judge’s final decision on the award?

    The word “rabid” is too tame to describe Oberlin’s attitude. Probably weighed heavily in the minds of the jury when contrasted to the Gibsons’ demeanor. Whatever amount gets awarded, it won’t be enough. These are evil people.

    Tom Servo in reply to Brave Sir Robbin. | July 16, 2019 at 11:36 am

    I am not impressed with Oberlin’s representation. This is such a huge and embarrassing loss it has to affect the firm’s reputation.”

    I agree – I imagine they were thinking “well it’s a big case, we’re going to make a lot” – but I think a lot of Oberlin’s arrogance bled over into their strategy. They just never took the defendants very seriously.

    And it’s never a good idea for a law firm to let their own reputation go down with a bad client’s ship. I’ve seen it happen a couple of times.

    maxmillion in reply to Brave Sir Robbin. | July 16, 2019 at 12:38 pm

    Oberlin’s outside counsel had an out-of-control client to whose lunacy they acquiesced, from all outward appearances.

    Penalty awards are not that common. But when there is a penalty, abuse of process is often part of it.

    For example, in the McDonald’s Coffee case, there was deliberate delay, in hopes that the plaintiff (an old lady with 3rd degree burns) would die, as well as argument that runs contrary to our own laws (she was injured because she was fragile, so her injuries were her fault).

    Abuse of process can be taken as an indicator of bad faith, and the need for a lesson.

It’s interesting that in the plaintiffs’ attorneys’ reply brief they point out that the court cases Oberlin’s attorneys rely on to urge denying attorneys fees were actually overturned later by the Ohio Supreme Court. I think the plaintiffs’ attorneys have earned every dollar they are asking for.

AlexanderYpsilantis | July 16, 2019 at 12:17 am

Enjoying every second of Oberlin’s suffering. They brought it down on themselves, now they have to pay the piper.

I can see this legal assault on the Gibsons, and the likely cost in the end of just the legal bills, $15M+, being more damaging to the future employment of Ambar, Varner, and all of the others who got them into this mess. It is just too clear at this point that there were no adults in the room. And anyone on the board who backed this game plan needs to go as well. Good luck telling the alumni that this particular case of BLM warranted the risk of $40M and the annual income loss of $1.6M, forever!!!!

    I can’t believe that there isn’t a legal avenue for going after the Board. I understand the control a college president can have over a Board but that is not a legal defense. At some point, the law has to determine what the standard of trust is for “trustees”. They are not enablers for criminals. They are custodians protecting “other people’s” money.

    If they can walk away from this scot-free, why even have a board of trustees? As a source patronage to reward people of influence who help raise money? It’s just one big scam on donors?

      It is my understanding that the board of trustees is the final authority on what happens in the college. In light of this, wouldn’t the insurance company have the standing to bring a breach of fiduciary duty action against the trustees?

      /s/JD Nobody, OC ’61

        That is my point. Just because it is a difficult case doesn’t mean someone shouldn’t try. Their insurance company has already declared that the insurance policy doesn’t cover this liability which is why the money will come out of the endowment funds. Why is that not an actionable example of abdication of responsibilities? Why should Trustees who cannot be trusted to protect the money they already custody be allowed to continue soliciting more contributions?

          This is an interesting situation. Trustees should have “Errors & Omissions” insurance provided by the College for their performance. If the Trustees had a reasonable opportunity to take action that demonstrably could have made a difference and failed to do so then some of the cost might be covered by their errors and omissions carrier. However, the case might be weak, as it looks like most of the college’s problematic actions were with respect to the demonstration right after the incident. It would be unreasonable to assume the Board could have done anything about that. However, the Board minutes better show thorough and timely discussion of possible settlement of the lawsuit, etc – and I bet they do.

          If the college and trustees have no meaningful insurance coverage for their FUBAR management it makes me even angrier.

          I am willing to cut President Ambar some slack in that Krislov compounded the mess for her before she took over. In all likelihood, the train had left the station long before she ever arrived.

          One thing that was never taught at Oberlin was how to ferret out what is really going on in an organization rather than just trusting what your subordinates tell you. Unless Ambar has that skill, she was led to the slaughter by her subordinates. After she asked her top-level subordinates what was going on she should have verified it by asking the janitors what was up. Only the janitors know what is in the wastebaskets.

          Assuming that on her arrival she had been told the whole truth about who did what and to whom, she had two options. First, she could have used her gravitas as a black woman to strongly and publicly state that the college did not regard the Gibsons as racist people and that when a few students attempted to sabotage the Gibsons’ livelihood this was an intolerable act on the part of individuals acting on their own and not on behalf of the college. Second, she could smile and keep as low a profile as possible.

          Even if one assumes that the Gibsons hate every black person alive, that does not justify the students’ efforts to destroy the Gibsons’ income and thereby their ability to feed their families. The college apparently feels that freedom of speech includes the right to destroy other people.

          Had Ambar taken her first option it would have ignited a firestorm with the PC people in the college. Moreover, they would have branded her a traitor and called her a generic oreo. She chose to attempt to prevent an insurrection at the expense of huge financial and public relations damage.

          The Puritan self-righteousness of Oliver Cromwell is once again alive and well and living in Oberlin. Oberlin’s finest are now bloated with righteousness and drenched in compassion. They are not to be sullied by the impersonal and insensitive rule of law, and are part of the new order wherein facts and opinions are the same thing.

          BTW, JD Nobody just obtained a copy of the police report on the initial robbery at Gibsons’. For those who have not read it, it is excellent background information. The incident was a lot more than just a shoplifting job. See https://ct.complexitytrap.org/wp-content/uploads/2019/07/Gibson-Robbery-1600621.PDF

          BTW, how about a class action by the alumni for the damages resulting from the college sullying our Oberlin credentials, which we have worn with pride until now?

          Now you can honestly say Nobody told you any of this.

          /s/ JD Nobody, OC ’61.

          J.D> Nobody, it looks like President Ambar may have taken your second choice. I think there might have been another path, not taken – to say very publicly that she was the new kid on the block, would be damned if her new administration and the College’s mission was going to be distracted and possibly seriously damaged by this and related publicity and had instructed her lawyers to resolve the matter. In my opinion, that is a leadership variation on your first choice that publicly avoids the blame game (although even $10M early on makes it sort of obvious).

    jb4 in reply to MajorWood. | July 16, 2019 at 1:35 pm

    I share your and everyone else’s view of this case. However, as a graduate of Oberlin when it produced very well-educated, critical thinkers and not what appears to be SJW and “snowflakes” these days, I hope that the final chapter has not yet been written. If the judgment and costs are paid and not appealed, the institution will then have the opportunity to demonstrate that recent years have been an aberration in the long history of a well-regarded institution. Consequently, I believe it is premature to write off the college, especially with near a billion in endowment and hundreds of millions worth of art. However, in my opinion, if they learn nothing from this experience, application and enrollment problems and decreased donations will eventually catch up with them.

I thought Universities were places of higher learning…these folks don’t seem to understand or learn.

Everyone is against you and the bill just keeps growing!

With an award of $25-million, a 40% contingency fee would be $10-million – which is in the range of fees that Gibson’s is seeking. The question comes down to whether the 40% contingency fee comes out of the settlement, or is in addition to the settlement.

I need a new rear window decal in Oberlin colors which says:

40 down, 960 to go

I attended and graduated from Oberlin (Dascomb, North, Tank- Yeomen will recognize my bona fides.) at the height of the “hippie era.” Back then there were activists galore, but it was a much more benign form of social activism. There was room for differing viewpoints and discussions could be intense, but in the end, we all pretty much just got along with each other. People were much more tolerant of opposing views and civil to those with whom we disagreed.

I will give credit where credit is due; I was well-educated at Oberlin. Nevertheless, for some time now all of the news concerning my alma mater has been negative. It is the butt of jokes all over the media. The words “Oberlin graduate” are now synonymous with “virulent, confrontational intolerance of any opposing views.” Oberlin is now recognized by many as the point of the anti free speech spear. Free and open discussion has been replaced by unfettered confrontational coercion by the dominant student faction on campus, including inside the classroom.

I am ashamed to tell people that I am an Oberlin graduate. Can burning books be that far off?

Colleges have a duty to serve their students real intellectual needs. It’s a lot less like a restaurant, where you can order exactly what you like every single meal, and more like your mother’s kitchen table. Mom made sure you ate your vegetables whether you liked it or not, not because she was some fascist hell-bent on oppression, but because she knew that a balanced diet was good for you and that, God forbid, you might discover that steamed broccoli was not quite as unpalatable as you expected it to be.

From my vantage point, Oberlin College has been derelict in its duties to its students. Now they’re paying the price for that dereliction. For me one question remains. “Is this judgement a loud enough wake-up call to get the attention of those whose position and oversight responsibilities require loyalty to free and open discussion on campus?”

At Oberlin “In loco parentis” has turned into just plain “loco.” Put away the non-stop mac and cheese. These kids need to try some broccoli, Mom.

    jb4 in reply to Hollymon. | July 16, 2019 at 3:06 pm

    I precede you a bit in time, but you hit the nail on the head. Tolerance seems in short supply in society these days, so it is hard to tell whether Oberlin is reflective of society, causative, or both. The phrase “distribution requirements” also seems in short supply and “XYZ studies” all too plentiful. I ate plenty of broccoli there and met lots of great, demanding teachers in those courses. In my opinion, one of the reasons Liberal Arts colleges are in trouble is that many no longer produce educated people with disciplined minds – more or less just advanced High School degrees. (The price is way too high for that.)
    In my opinion, Oberlin needs to go back to its roots that we got the benefit of and attempt to lead the nation’s liberal arts colleges out of the wasteland they now find themselves. That would be risky. However, what is the need for the current Oberlin to exist, especially at $70+K retail price in its location?

    JusticeDelivered in reply to Hollymon. | July 16, 2019 at 8:29 pm

    Oberlin College has devalued their degrees, what we don’t know is this a blip or permanent. How long before we see a class action by unemployable students?

    I don’t think this will hurt former student with a significant work history, but it might hurt more recent graduates. At this point, if I was hiring I would probably pass on an Oberlin student, figuring they are likely to be trouble.

      What are the chances of someone with deep pockets bringing a breach of fiduciary action against the trustees for letting this incredible mess snowball and fester for years? The college will be out millions because the trustees did not tell the administration to distance the college from the lunatic fringe in the student body.

      /s/ JD Nobody, OC ’61

        MajorWood in reply to J.D.Nobody. | July 17, 2019 at 12:07 pm

        I think it is important to note that we still don’t know exactly what happened, why, and by whom. This was a simple shoplifting incident that got out of control to such a degree that outside forces pushing a purposeful agenda seems obvious. Was it placating students, improving the woke image, or just a bunch of parking spaces? After all of this we still don’t know. And it likely started from the get-go, with legal counsel provided for Aladin, and even continued through to having a college representative at the shoplifting trial 10 months later. Was there anything normal about any of this? For something that the college claims that they had no role in, they sure kept pretty tight tabs on the doings.

        Last night I explained to my teenage son that had the college kept clear of this, the entire thing could have been resolved in a few months for perhaps $5,000, which would encompass the fines the students paid and a minimal amount of legal advice. But by getting involved and trying to cut corners, the college managed to make it an ongoing (still ain’t over) 3 year process which will likely end up at 8,000 times the original cost. Eight Thousand Times! That doesn’t happen by chance or accident. That requires sustained effort.

        And yet no mastermind has stepped forward to claim responsibility on the college’s side. They know that the day of reckoning is coming, and it is probably why they wanted another 45 days of continuance just to avoid the inevitable as long as possible. Yeah, 45 days from now, when this new legal fees bombshell hits, people will have forgotten all about that little $25M kerfuffle in June. /s So for me, this isn’t over until the responsible parties have been outed and purged from the system. Obviously, the ongoing litigation has kept anyone from making any moves that might affect the outcome. But as it becomes apparent that Oberlin will not appeal, well, to adults at least, it seems likely that we will enter the internal blame-game phase. Someone needs to be held accountable and that whole process could be as interesting as the trial. So, who will break first? Will there be public infighting on the board? If all 30 or so members endorsed this trial, then all 30 need to go, but I doubt that it was unanimous and perhaps some who were against the scorched earth policy will come forward with their side. And part of me wonders if a small faction took it upon themselves to direct these events independent of the rest of the board? I for one have not put away the popcorn maker. There is potential for serious drama here. Hampshire College on crack? And the best part, to keep it under wraps will require Oberlin to make concessions to involved parties, which in and of itself may become an even bigger scandal when, not if, it is revealed. Double-down baby, double-down. My predictions right now are that Raimondo will “resign” in the near future to “move on to better opportunities” and that the college will provide her with a golden parachute of 2-3X annual income to assist her during the transition. If they have to buy her silence, then it strongly suggests that there is something to be silent about. This is the downside of lying and secrets. The consequences do not stop until the truth comes out. And as soon as one person gets paid off for silence, then the rest will demand their share. I predict that this will continue to cost the cost college for years to come. They may choose to view it as prudent expenditures to preserve the reputation, but I see it as a shakedown, and just so ironic as that was the likely tactic against Gibsons from the start. Time wounds all heels. And they are all self-inflicted wounds.

          MajorWood, I think that the main problem is institutional, involving the students, faculty, administrators and Board that they have, rather that any one or a few individuals. That makes the blame game really tough. But to play it, in line with your post, former President Krislov is most handy, as not being there any longer and in charge at the time. Next is Raimondo, a key figure in the case. My final pick would be the General Counsel, under whose legal watch this mountain of money was lost. You might see some Board resignations if some of the possibilities at the Board level that you mention did occur. I would be quite surprised if Ambar goes. Taking no action at all would, in my opinion, give the worst long term result.

          Re exactly what happened, the police report is at https://ct.complexitytrap.org/wp-content/uploads/2019/07/Gibson-Robbery-1600621.PDF

          One thing JD Nobody’s freshman physics lab instructor taught his students was the following:

          There was a masculine girl from Khartoum,
          Who invited a feminine boy to her room.
          They spent the whole night
          In one hell of a fight
          Over who should do what, and to whom.

          That poetic tradition lives on with the trustees today, because:

          They’re all poets
          And don’t know it
          But their toes show it.
          They’re Longfellows.

          Now you can tell the world that Nobody told you all this.

          /s/JD Nobody, OC, ’61, Poet of the physics department and gadfly of the chemistry department.

          jb4 in reply to MajorWood. | July 17, 2019 at 2:50 pm

          J.D. Nobody, wasn’t Norman Craig great?!

          jb4, Norm Craig is great. Saw him just a few days ago.
          BTW, JD Nobody did get the better of him at least once in freshman chem lab.

          /s/JD Nobody, OC ’61.

          J.D. Nobody, Organic was probably my favorite course at Oberlin, with Craig I recall – loved both the course and, especially, the lab; but ended up in Math, with a Chem minor.

    puhiawa in reply to Hollymon. | July 17, 2019 at 2:57 am

    My sister says the same thing about Scipps College, Claremont, CA.

Comanche Voter | July 16, 2019 at 11:13 am

I dunno. I hope the attorney’s fees are in addition to the damage reward. If the attorneys get paid twice, they put up with a lot of guff from Oberlin’s counsel. Deposing a 90 year old man for 19 hours over five days is a sort of judicially sanctioned waterboarding.

I don’t recall hearing about the amazingly long and pointless depositions — I had to search to find out who Dr. Roy Ebihara even was, and how on earth could he have been deposed on multiple days I can’t imagine. I would think that this would have been really annoying to listen to in the courtroom. Was this another reason the jury got so annoyed with Oberlin?

JusticeDelivered | July 16, 2019 at 8:33 pm

Maybe the judge should make this easier on Oberlin College, just ward the Gibsons that $150 million statue 🙂

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