Deposition Obstruction: Breaking Through | The American Association For Justice

Deposition Obstruction: Breaking Through

Mark Kosieradzki
AAJ Press

Our courts have carefully designed rules of discovery that guarantee equal access to the facts for everyone. These rules aren’t aspirational. They are rules of engagement designed to get to the truth. They recognize the reality of human conflict, and they channel the passions of those conflicts into controlled forums. If these rules are ignored, litigation becomes nothing more than an adolescent food fight. This book is what every trial lawyer needs to stand up to deposition obstruction and discover the truth on behalf of their clients. It is the most important tool you will have to assist you to understand the rules and case law that govern depositions. 

Price: $114.99 (plus $10 shipping and applicable sales tax for the paperback book)

**Please note: due to COVID-19, shipping of print books will be delayed.  We are still processing orders.  This book is available in e-book format for immediate delivery.**

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For help ordering the book, call (800) 622-1791 or (202) 965-3500, ext. 8612.


Praise for Deposition Obstruction

Mark provides solid, practical, and ethical ways to stop obstructions in deposition, but he does so much more.  This book is a primer on all aspects of taking proper depositions under the rules.  Every litigator should have a copy.

--Mark Lanier, recipient of the American Association for Justice Lifetime Achievement Award


The birth of a classic—a manifesto of freedom from ever again being shoved around in a deposition.

--David Ball, author of David Ball on Damages 3

View all the testimonials, here.

Table of Contents

To view the full table of contents, click here.

  • Introduction

  • Chapter 1: Purpose and Scope of Depositions

  • Chapter 2: Deposition Logistics

  • Chapter 3: Deposition Ethics

  • Chapter 4: Proper Objections

  • Chapter 5: Prohibited Objections

  • Chapter 6: Instructions Not to Answer

  • Chapter 7: 30(b)(6) Scope of Testimony

  • Chapter 8: Attorney-Client Conferences

  • Chapter 9: Sanctions

  • Appendix A: Federal Rules of Civil Procedure 1, 26, 30, 32 & 37

  • Appendix B: Comparing Relevant Portions of Rules 30 & 32