Friday, September 26
Registration (Continental breakfast)
8:00 am-8:30 am
Welcoming Remarks and Introductions
8:30 am-9:00 am
Developing a Discovery Plan
- Who, what, when, where, and why to depose
- The written plan
- Sequencing your discovery
- Identifying your weakness
Addressing Bias in Depositions
- How bias affects your deposition strategy
- Using the deposition to overcome juror bias
Ten Rules for Effective Depositions
- Controlling the environment of the depositions
- Developing goals
- Obtaining material for cross
Adverse Lay and Expert Witness Depositions: Techniques of
Exhaustion, Boxing-in, Summarization
- Making the witness tell you everything he or she knows
- Summarizing techniques to keep the witness from changing
his or her testimony
- Cementing the witness's testimony
Workshop Introductions and Networking Lunch
12:15 pm-1:45 pm
Organizing for Depositions and Planning Tactics
- Creating a deposition notebook
- Using documents and learned treatises
- Exploiting the opponent's weaknesses
Workshop on Taking Depositions
Networking Reception
6:00 pm-7:00 pm
Saturday, September 27
Continental breakfast
8:00 am-8:30 am
Morning Session
8:30 am-11:45 am
Developing Your Theme in Discovery
Structuring the Deposition of a Difficult Witness
- How to identify the difficult witness
- How to control the difficult witness
- The one fact, one question approach
- How to deal with nonresponsive answers
General Considerations for Witness Deposition Preparation
- Special considerations for client preparation
Record Depositions and Rule 30(b)(6)
- Deposing the "corporation"
- Depositions by designation
- Structuring a 30(b)(6) notice
Lunch (on own)
11:45 am-1:00 pm |
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Saturday, September 27 (cont'd)
Afternoon Session
1:00 pm-5:30 pm
Dealing with the Difficult Situation and Attorney (ethics)
- Hall v. Clifton Precision Tools
- Handling objections
- Instructions not to answer
- Calling the judge
Workshop on Deposing the Lay Witness
Sunday, September 28
Continental breakfast
7:30 am-8:00 am
Morning Session
8:00 am-1:15 pm
Deposing the Defense Medical Examiner
- Gaining concessions
- Developing cross material
- Obtaining information for use by your expert
- Discovery of economic interest
Later Use of Depositions at Settlement and Trial
Workshop on Deposing Expert Witnesses (Lunch will be provided)
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