Employee’s goals in deposing the harasser

The wronged employee’s lawyer has three primary goals in taking the deposition of the harasser. The first goal (which invariably is never achieved) is to get the harasser to admit to the harassing conduct. The second goal is to discover the harasser’s “story” so that you can figure out how to disprove that “story.” The third goal is to get the harasser to admit that the defendant-employer never took any disciplinary action against him as a result of the plaintiff’s (the employee who was harassed) complaints, others’ complaints, or the defendant-employer’s investigation. Such an admission will help you argue that the defendant-employer ratified the harasser’s conduct by failing to take any action against him.