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Questioning Strategies for Litigators: Depositions, Voir Dire, Cross-Examination and More Webinar

presented by NBI, Inc.
View the NBI, Inc.


Questioning Strategies for Litigators: Depositions, Voir Dire, Cross-Examination and More

Workshop Description/Agenda

Master the Art of Questioning

Whether you're interviewing clients and witnesses, conducting a cross-examination or questioning potential jurors at trial, being able to draw out the answers you need is a vital skill for any litigator. However, perfecting the art of questioning is an elusive goal. Every witness is unique, and there can be a fine line between drawing out the answer you want and unleashing a torrent of unhelpful or even harmful information. In this program, trial lawyers who have spent years honing their questioning techniques will show you what questions to ask and how to ask them so you can get precisely what you need. Enhance your advocacy skills - register today!

  • Learn how to seamlessly blend psychology into your questioning strategy for better results.
  • Discover questions you should not ask and how to avoid that one question too many.
  • Get jurors talking and find out how to unmask their hidden biases and attitudes.
  • Admit (or exclude) exhibits and expert witnesses by laying the most effective foundations.
  • Draw out admissions and defuse harmful testimony on cross.
  • Find out how to detect and draw honest answers out of the lying or evasive witness.

This is a rebroadcast of the original webcast delivered by Jan I. Berlage, Glenn A. Duhl and Daniel Torrens on March 20, 2020. Faculty will be available to answer your questions after the program.


10:00 am to 5:00 pm Eastern Standard Time

  1. Questioning Tactics (and Pitfalls) Every Litigator Needs to Know
    10:00 - 10:30, Daniel Torrens
    1. Top 10 Tactics That Should be in Every Litigator's Arsenal
    2. Applying Psychology in Your Questioning Strategy
    3. Common Questioning Mistakes That Can Hurt Your Case
  2. Deposition Questioning Techniques: Obtaining the Information and Testimony You Need
    10:30 - 11:15, Glenn A. Duhl
    1. Questioning Techniques, Wording, Question Structure, Order, etc.
    2. Lines of Questioning
    3. Obtaining Crucial Information and Eliciting Concessions
    4. Drawing Out the Evidence You Need to Get Testimony Excluded
    5. Setting Up Later Trial Impeachment
    6. Dealing with Objections and Obstructionist Tactics by Opposing Counsel
  3. Voir Dire: Questions and Strategies to Uncover Hidden Biases
    11:30 - 12:15, Glenn A. Duhl
    1. Juror Questionnaires, Research and Prep
    2. Boundaries and Limits on Questions - Rules and Judge's Preferences
    3. Questioning Potential Jurors - Styles and Techniques
    4. Eliciting Biases and Laying the Groundwork for Cause Strikes
    5. Identifying Their Best Jurors Without Unmasking Your Own
    6. Getting Honest Answers to Tough Questions
    7. Planting Your Own Ideas & Persuading Through Voir Dire Questions
    8. Observing Juror Reactions - Verbal and Nonverbal
  4. Foundational Questions: Getting Exhibits and Testimony Admitted Into Evidence
    12:15 - 1:00, Jan I. Berlage
    1. Proper Lay and Expert Opinions
    2. Qualifying the Expert Witness
    3. Direct Examination: Solidifying Your Story and Witness Credibility
    4. Laying a Foundation for Documentary Evidence
    5. Social Media Posts, Texts, Emails and More: Sample Foundation Questions/Scripts
    6. Physical, Demonstrative and Illustrative Evidence
  5. Making Objections and Preparing Your Witnesses to Avoid Traps
    1:30 - 2:00, Glenn A. Duhl
    1. Preparing Witnesses for Tricky Questions
    2. Tips for Preparing Difficult Witnesses
    3. Defending Depositions and Making Objections
    4. Objecting to Testimony at Trial
  6. Cross-Examination: Eliciting Favorable Admissions and Undercutting Harmful Testimony
    2:00 - 2:45, Jan I. Berlage
    1. Questioning Tips and Tactics for Cross-Examination
    2. Gaining (and Maintaining) Control
    3. Setting Up the Witness
    4. Forcing the Witness to Answer Questions Harmful to an Adversary's Case
    5. Destructive Cross-Examination - Destroying Credibility
    6. Words and Questions That Can Backfire
    7. Knowing When to Stop Asking Questions
  7. Questioning Experts and Difficult or Special Witnesses
    2:45 - 3:15, Jan I. Berlage
    1. Strategically Questioning an Expert Witness
    2. Exposing Expert Bias and Lack of Qualifications
    3. Types of Difficult Witnesses and the Tactics They Use
    4. Cross-Examining Difficult Witnesses
    5. Controlling the Runaway or Explaining Witness
    6. Questioning Children and Other Special Witnesses
  8. Lies, Evasion and Omissions: Exposing and Dealing with Deception
    3:30 - 4:00, Daniel Torrens
    1. Detecting Lies and Deception: Tips From a Seasoned Trial Attorney
    2. Identifying Micro-Expressions and Ignoring False Cues
    3. Confronting Lying Behavior
    4. Dealing with the Lying or Evasive Witness
    5. Questioning Strategies to Draw Out Honest Answers
  9. Legal Ethics
    4:00 - 5:00, Daniel Torrens
    1. Preparing vs. Improperly Coaching Witnesses
    2. Advocacy vs. Misrepresentation: Applying ABA Model Rules
    3. When Aggressive Litigation Tactics Cross the Ethical Line
    4. Juror Investigation and Communication
      1. Competence and Diligence
      2. Avoiding Jury Tampering
    5. Legal Ethics of Social Media and Data Mining

Who Should Attend

This program is designed for attorneys. Paralegals may also benefit.

Additional Information

Training Provider: NBI, Inc.

Course Topics: Law Training > Trial Practice

Training Course Summary: Questioning Strategies for Litigators: Depositions, Voir Dire, Cross-Examination and More

Live Webinar Date/Time