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Advanced Deposition Tactics

presented by NBI, Inc.
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Advanced Deposition Tactics

Workshop Description/Agenda

Take Your Skills to the Next Level

Make your depositions more fruitful! Whether you're trying to ascertain facts, size up a witness, or capture testimony that can be used to impeach, our seasoned faculty will reveal time-tested strategies for achieving your goals. You will also learn creative techniques for defending depositions. Get the tactics you need to obtain killer testimony or help your witness withstand aggressive questioning by opposing counsel - register today!

  • Learn where to go to find even more information or dirt on the deponent.
  • Apply creative questioning styles and techniques to get the testimony you want.
  • Avoid and undermine answers that are harmful to your client's case.
  • Find out how to steer expert witness testimony with precision.
  • Tailor your strategy: learn techniques that work with different types of deponents.
  • Get tips for dealing with opposing counsel that is being overly obstructive or aggressive.
  • Find out how to best prepare witnesses for the trick questions.


All times are shown in Eastern time.

  1. Preparing for Depositions: Creative Insights
    11:00 - 11:30, Steve Bruderle
    1. Finding a Wealth of Information on the Deponent
    2. Outline Pointers
    3. Anticipating Evidentiary Issues
    4. Potential Problem Areas and How to Handle Them
    5. Controlling the Environment
  2. Deposition Questioning Strategies and Tactics
    11:30 - 12:30, Steve Bruderle
    1. Style of Questioning, Form of Questions
    2. Organizing Your Questioning - the Funnel Technique
    3. Boxing-In and Exhaustion Strategies
    4. Timeline Techniques
    5. Preserving Your Strongest Questions
    6. Successfully Handling Objections
    7. Eliciting and Cementing Helpful Answers
    8. Fertile Ground for Useful Admissions
    9. Undermining Harmful Answers
  3. The Art of Expert Witness Depositions
    12:45 - 1:30, Zachary B. Pyers
    1. The Report
    2. Finding Impeachment Material
    3. Key Techniques for Taking Expert Depositions
    4. Killer Deposition Questions for Expert Witnesses
    5. Tips for Defending Expert Depositions
  4. Dealing With Different Types of Witnesses
    1:30 - 2:30, Howard A. Rothenberg
    1. Forgetful, Confused or Evasive Witnesses
    2. Deponents Who Respond With Vague Answers
    3. The Liar
    4. Tactical Approaches to Inconsistent Statements
    5. Deponents Who Talk Too Much
    6. Uncooperative Witnesses
    7. Hostile or Arguing Witnesses
    8. The Child Witness
    9. Deponents With Mental Health Conditions or Diminished Capacity
  5. Rambo Depositions: How to Deal With Difficult Opposing Counsel
    3:00 - 3:30, Howard A. Rothenberg
  6. Defending Depositions: Tips From a Seasoned Litigator
    3:30 - 4:15, Gerald A. Connor
    1. Things You Should Always Tell Deponents
    2. Preparing Deponents for Tricky and Difficult Questions
    3. Leveraging Objections
    4. Intervention: Opportunities, Timing and Pointers
    5. Going Off the Record
    6. Instructing the Witness
  7. Mastering the Remote Deposition
    4:30 - 5;00, Zachary B. Pyers
  8. Deposition Ethics
    5:00 - 6:00, Gerald A. Connor
    1. Preparing vs. Coaching a Witness
    2. Candor: When a Client or Witness Lies
    3. Keeping it Civil
    4. Collecting Information About Deponents: Ethical Issues
    5. Representing the Non-Party Witness
    6. Prohibited Communications and Solicitations
    7. Ethics Concerns With Remote Depositions

Who Should Attend

This program is designed for attorneys.

Additional Information

Training Provider: NBI, Inc.

Course Topics: Law Training > Paralegals

Training Course Summary: Advanced Deposition Tactics