Depositions College: Sharpening Your Skills

Developing a Discovery Plan

• Who, What, When, Where, and Why to Depose
• The Written Plan
• Understanding the Legal Framework

Techniques of Exhaustion/Boxing-In, and Restating

• Making the Witness Tell You Everything He or She Knows
• Cementing the Witness' Testimony

Faculty Q&A

Workshop: Exhaustion, Boxing-In, and Restating

Techniques of Summarization

Summarizing techniques to keep the witness from changing his or her testimony

How to Use Exhibits to Enhance Your Deposition Skills and Prepare for Trial

• Document Combining

• Marking Up Exhibits

• Sharing Exhibits

Faculty Q&A

Workshop: Summarization and Using Exhibits

Identifying the Rules & Standards

• Finding and Drafting Rules

• Standards of Care

Structuring the Miller Mousetrap

Faculty Q&A

Workshop: Rules and the Miller Mousetrap

Techniques for Dealing with Difficult Witnesses and Evasive Witnesses

• How to identify and control the difficult witness
• The One Fact, One Question Approach
• How to Deal with Nonresponsive Answers

Ethical Considerations for Dealing with Deposition Obstruction

• Proper and Improper Objections: Legal and Ethical Considerations
• How to Effectively Handle Obstructive Tactics
• Sanctions and Other Creative Tactics to Deter Obstructive Behavior

Faculty Q&A

Workshop: Dealing with Difficult Witnesses, Evasive Witnesses, and Objections