Westin Canal Place
New Orleans, LA
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Built on the fundamentals of AAJ's Depositions College, the Advanced Depositions College provides an in-depth, cutting-edge approach to perfecting depositions and witness preparation skills.
Friday, January 13
Registration (continental breakfast available)
7:30 – 8:00 am
Morning Session
8:15 am - 1:15 pm
Welcome and Introductions
Understanding Bias and Its Role in Discovery and at Trial
- How bias affects your deposition strategy
- Combating bias in discovery and trial
- Finding your reptilian issues through discovery
Paul Scoptur
Establishing Standards of Care and Conduct with Defense Witnesses
Paul Scoptur
Workshop: Discovery Plan and Witness Goals
- Witness plan
- Goals for each lay witness—three take-aways
Networking lunch
12:15 – 1:15 pm
Afternoon Session
1:15 - 5:45 pm
The Importance of Video
Erik Heninger
Deposition Techniques
- Exhaustion
- Boxing-in
- Restating and summarizing
- Nonverbals, mirroring
Phillip Miller
Deposing the Difficult Witness
- One fact, one question
- Using exhibits for control
- Establishing deposition protocol/rules
Robyn Wishart
Workshop on Lay Witnesses: Exhaustion, Boxing-in, Restating and Summarizing, Nonverbals, Mirroring
Networking Reception
5:45 – 6:45 pm
Saturday, January 14
Morning Session (Continental Breakfast Available)
8:00 am - 1:00 pm
“Death Star” Depositions: The 30(b)(2) Deposition
- Finding all the documents
- Using a 30(b)(2) deposition to discover case dispositive information
- Altered records: lock the defendant in, then impeach with the originals
- Using the “smoking gun” document
Paul Scoptur
Depositions of Corporate Representatives: 30(b)(6) Deposition
- Crafting the notice for your case; for contention depositions related to defenses;
demonstration of questions to establish the witness speaks for the corporation;
relationship between Rules 30(b)(6) and 32
- Setting the Course for Trial and Making the Plaintiff’s case: The 30(b)(6) Deposition
Strategy, Goals, and Techniques to Nail the Defendant
Erik Heninger
Jerry O’Neill
Workshop: Document Discovery/“Death Star” Depositions
Lunch (on your own)
1:00 – 2:00 pm
Afternoon Session
2:00 - 5:15 pm
Demonstration: Dealing with the Evasive Witness
- Techniques in handling the evasive witness
- Demonstration of deposing the evasive witness
Stacey Mullins
Jerry O’Neill
Workshop: Establishing Standards of Care and Conduct
Sunday, January 15
Morning Session (Continental Breakfast Available)
8:00 am - 12:30 pm
Dealing with the Rambo Litigator (ethics)
- Use of ethics rules
- Use of deposition protocol
- Redwood v. Dobson
Lance Sears
Witness Preparation (Including a 10-minute break)
- Learning styles
- Processing styles
- Making your witness defamation proof
- Diagnosing witness’s problems and issues
Charlotte Morris
12:30 – 1:30 pm Lunch (on your own)
Afternoon Session
1:30 - 5:30 pm
Special Considerations for Deposing Experts
- Establishing facts and theories favorable to your case
- Daubert
- Silver bullets
Jerry O’Neill
Workshop: Deposing Experts
Microexpressions and Body Language
Phillip Miller
Monday, January 16
Morning Session (Breakfast Buffet Available)
8:00 am - 12:00 pm
How to Effectively Use Your Depositions in Trial
- Maximum effect as impeachment
- Substantive evidence when the witness is unavailable
- In opening and closing using PowerPoint
Stacey Mullins
Faculty Deposition Demonstrations
• Deposition of accident reconstruction expert
Phillip Miller
• Deposition of defendant driver
Robyn Wishart
• Deposition of DME
Paul Scoptur
Bringing It All Together
- Summarization of key points from each lecture
- Vignettes for key points
