Rules of the Road for Discovery, Depositions, and Mediations | The American Association For Justice

Rules of the Road for Discovery, Depositions, and Mediations

May 10, 2019 to May 11, 2019
Program Information:

La Fonda on the Plaza | Santa Fe, NM

Sponsored by Synergy Settlement Solutions
Sponsored by Lisa Blue and Williams Kherkher

About the Seminar:

AAJ Education’s best-selling seminar returns to beautiful Santa Fe, NM, with a newly expanded focus on discovery, depositions, mediations, and more! This seminar is based on Patrick Malone and Rick Friedman’s Rules of the RoadTM, one of the best-known books on proving liability. Learn how to apply the Rules to the critical early stages of your case, focusing your investigation and discovery on the most productive and persuasive ways to shape your case, and then carry it through to successful resolution. Specific topics include innovative investigative techniques that don't require your adversary’s cooperation, taking tighter and more persuasive depositions, inside secrets from the mediator, and much more.

Registration Fees:

$995 for AAJ Members 

Online registration for this program has closed. Registration is still available onsite at La Fonda on the Plaza Hotel. 

If you are an AAJ member and have been admitted to the bar for five years or less, you can attend this seminar for 50% off. (Does not apply if you have previously attended an AAJ Education seminar or college). This discount is not available online, please call 800-622-1791 for more information.
AAJ Paralegal Affiliates may attend this seminar and receive 50% off the registration fee if they are employed by and attending with an AAJ plaintiff attorney from the same firm with the same firm address. This discount is not available online, please call 800-622-1791 for more information.

Contact AAJ Education: 800-622-1791 | 202-965-3500, ext. 8612 |​​


Friday, May 10

Registration and Welcome Networking Breakfast
7:30 - 8:30am

Morning Session
8:30 - 11:45am
• Using Rules of the RoadTM to Focus and Shape Your Discovery Plan
• Deposing Difficult Witnesses, and Making Them Agree to Your Case Rules

Networking Lunch
11:45am - 12:45pm

Afternoon Session
12:45 - 4:45pm
• Corporate Spokespersons: Unlocking Pandora’s Box with Rule 30(B)(6)
• Using the Rules of the RoadTM to Win Your Case in Deposition
• Trucking Cases: Nuts and Bolts and a Lot More

Networking Reception
5:30 - 6:30pm

Saturday, May 11

Welcome Back Networking Breakfast
7:30 - 8:30am

Morning Session
8:30am - 1:30pm
• Electronic Medical Records: Everything You Need to Know
• Finding Killer Documents, Rules, and Evidence Off the Grid When They Don’t Answer Your Discovery
• The Ten-Minute Rule for Depositions: Shorter, Tighter and Far More Persuasive
• An Insider’s View: Secrets from the Mediator on Maximizing Your Client’s Recovery

Invited Faculty:

Jennifer L. Keel

Jennifer Keel focuses her practice on catastrophic injury cases, medical malpractice, birth trauma, brain and spinal cord injuries, and other surgical errors resulting in injury and/or death. she is an expert on electronic medical records evidence and audit trail use in medical negligence litigation, and teaches lawyers across the country how to obtain and make use of this critical evidence. She has a unique background studying biology and biochemistry in her undergrad and was a paramedic from 1995-2001. her cumulative experiences in patient care provide a distinct advantage to her clients: her broad base of knowledge of medicine and medical and surgical standards and techniques offers context within which to analyze and prosecute cases. Thomas, Keel & Laird LLC, is located in Denver, Colorado.

Mark R. Kosieradzki

Mark R. Kosieradzki is the author of 30(B)(6): Deposing Corporations, Organizations & the Government; Depositions Obstruction: Breaking Through; and the AAJ Deposing the Corporate Representative: 30(b)(6) Depositions DVD. He has joined trial teams throughout the United States, assisting them with all aspects of the 30(b)(6) depositions in their cases. His experience covers a wide variety of wrongful death and catastrophic injury cases, including malpractice, bad faith, construction injuries, nursing home abuse, interstate trucking accidents, and products liability. He is recognized in the “Best lawyers in America”. He is a board certified Civil Trial Specialist by the National Board of Trial Advocacy and the Minnesota State Bar Association. He is also a member of the Multi-Million Dollar Advocates Forum. He is a past president of the Minneapolis Association for Justice, and a past president of the Minnesota Chapter of the American Board of Trial Advocates (ABOTA). The Kosieradzki Smith Law Firm, LLC, an AAJ Leaders Forum firm, is located in Minneapolis, Minnesota.

James B. Lees, Jr.

James B. Lees, Jr. is a former co-chair of AAJ’S National College of Advocacy Board of Trustees, a Diplomate of AAJ’s NCA, an AAJ PAC donor, and a frequent lecturer and teacher of trial tactics throughout the United States. He is a nationally recognized trial attorney and communications consultant, a graduate of Wake Forest University School of Law, and a former Deputy District Attorney in Pittsburgh, Pennsylvania, where he successfully prosecuted 44 first degree murder cases and six death penalty cases. In private practice since 1984, Mr. Lees has litigated both civil and criminal cases throughout the United States and has tried over 250 jury trials to verdict. Together with Alabama-based attorney Greg Cusimano, Mr. Lees created the five-part DVD series Commanding the Courtroom, the quintessential “how-to” video series for litigation and case development strategy, available from the American Association for Justice. Mr. Lees now consults frequently throughout North America on persuasive communications for attorneys, businesses, and political candidates and has lectured on the use of psychology and persuasion in over thirty states in the United States, as well as in British Columbia and Alberta, Canada. He has personally conducted over 900 focus groups over the past decade and has appeared as a guest on ABC’s Good Morning America, anchored a state-wide radio talk show, taught persuasion techniques at Harvard Law School, and written a monthly newspaper column. Mr. Lees ran for governor of West Virginia in 2000 and is the owner and operator of Hunt & Lees, LC, located in Charleston, West Virginia.

Patrick A. Malone, course advisor

Patrick Malone is a leading patient safety advocate and attorney who represents seriously injured people in medical malpractice lawsuits, product liability cases and other types of lawsuits. He is the co-author of an acclaimed book teaching other attorneys how to win cases: Rules of the Road: A Plaintiff’ Lawyer’s Guide to Proving Liability and The Fearless Cross-Examiner. He is a member of the American Association for Justice’s (AAJ) Federal Tort Liability Section; Professional Negligence Section; Birth Trauma Litigation Group; Jury Bias Litigation Group; and Traumatic Brain Injury Litigation Group. Mr. Malone is also the Treasurer of the Pound Civil Justice Institute; Board of Governors; Public Affairs Committee; and Press Advisory Board. Patrick Malone & Associates, a Leaders Forum Firm, is located in Washington, DC.

Randi McGinn, course advisor

Randi McGinn is the senior partner in the law firm of McGinn, Carpenter, Montoya & Love, P.A. She is known for her creativity in the courtroom and use of demonstrative evidence to visualize opening, direct, cross-examination, and closing argument. Ms. McGinn is past-president of the New Mexico Trial Lawyers Association and a member of the International Academy of Trial Lawyers, vice president of the Inner Circle of Advocates, and a member of the American Board of Criminal Lawyers. Ms. McGinn is a member of the American Association for Justice’s Press Advisory Board and National College of Advocacy Board of Trustees. McGinn, Carpenter, Montoya & Love, P.A., is an AAJ Leaders Forum member and is located in Albuquerque, New Mexico.

Brian McKeen

Brian McKeen focuses his practice on personal injury litigation, medical malpractice, and drug product liability. He has tried cases throughout the United States and currently sits on the executive boards of the Michigan Association for Justice and the American Association for Justice. He is a former chair of AAJ’s Professional Negligence Section, Medical Negligence Exchange Group, and Birth Trauma Litigation Group. He is also a member of the prestigious Inner Circle of Advocates and International Society of Primerus. McKeen & Associates, PC, an AAJ Leaders Forum firm, has offices in Detroit, Michigan, and Ottawa, Ohio.

Robert R. Michael

Robert R. Michael is admitted to the State and Federal trial and appellate level courts of Maryland, the District of Columbia, West Virginia, and the Supreme Court of the United States. He is a member of the very prestigious Inner Circle of Advocates (limited to 100 of the best personal injury lawyers in the United States); the International Academy of Trial Lawyers (limited to 500 lawyers around the World); is a Fellow in the American College of Trial Lawyers (limited to the top 1% of the trial bar); is a member of the select American Board of Trial Advocates; listed since 1986 in the publication Best Lawyers in America; listed in the Washingtonian Magazine as one of Maryland’s top medical malpractice lawyers; listed as one of Maryland’s Top Ten Lawyers in the Maryland Super Lawyers publication; listed as one of Washington, D.C.’s Top Ten Lawyers in the District of Columbia Super Lawyers publication; is listed in Who's Who in American Law, Who's Who in the East, Who's Who in Emerging Leaders, and Who’s Who in the World. He is a past president of the Maryland Trial Lawyers Association (1982); is a founder and was the first attorney president of the Montgomery County Chapter of the American Inns of Court in 1991; is a past member of the Trial Courts Nominating Commission for Montgomery County; is a past president of the Montgomery County Bar Association (1995-1996); is a past president of the Montgomery County Bar Association Foundation (1996-1997); and is a member of the Trial Lawyers Association of Metropolitan Washington, DC. In 2004 he received the Maryland State Bar Association Pro Bono Service Award for his work on behalf of the worst burn survivor of the 911 attack. He is a past Chair of the Litigation Section of the Maryland State Bar Association. He was also a member of the Court of Appeals Standing Committee on Rules of Practice and Procedure (2003-2013). He was a founding member of the national public interest law firm, Trial Lawyers for Public Justice, and is a member of the Roscoe Pound American Trial Lawyers Foundation, the Maryland State Bar Association Foundation and the American Bar Association Foundation. Mr. Michael is a prolific author and lecturer in the areas of personal injury litigation, professional negligence, and products liability litigation, including contributions to the Maryland Bar Journal, Maryland Tort Damages (Fourth and Fifth Edition), Maryland Automobile Accident Deskbook, Product Liability Law in Maryland, and Closing Argument: The Art and The Law, Clark, Boardman & Callaghan. He is the current editor of the Maryland Tort Damages publication.

Phillip H. Miller

Phillip H. Miller has an exclusively personal injury practice. Mr. Miller has handled a wide range of cases including trucking litigation, nursing home claims, pharmaceutical torts, and day care center child abuse. In addition to his law practice, Mr. Miller has extensive experience working as a trial consultant on a wide variety of cases. He is a former member of the American Association for Justice’s (AAJ) National College of Advocacy (NCA) Board of Trustees, a Diplomate of AAJ’s NCA, and a past president of the Tennessee Association for Justice. Mr. Miller is a member of AAJ’s Jury Bias Litigation Group. He is the co-author (with Paul Scoptur) of Focus Groups: Hitting the Bull’s-Eye (AAJ Press 2016); Advanced Depositions Skills (AAJ Press/Trial Guides 2013), has produced a DVD of the same title, and a DVD on The Defense Medical Examiner.  Miller Law Offices is located in Nashville, Tennessee.

Carl L. Solomon

Carl Solomon concentrates his practice in products liability, personal injury, civil, and medical negligence litigation. He is a member of the American Association for Justice (AAJ), South Carolina Trial Lawyers Association, the South Carolina Bar Association, and the American Bar Association. He previously served on AAJ’s National College of Advocacy Board of Trustees and is a past chair of AAJ’s Motor Vehicle Collision, Highway and Premises Liability Section. Mr. Solomon is admitted to practice in South Carolina and the U.S. District Court of South Carolina. Mr. Solomon also is an AAJ PAC M Club contributor.  He is “AV” rated by Martindale-Hubbell and listed in Super Lawyers and Best Lawyers in America. The Solomon Law Group, an AAJ’s Leaders Forum firm, is located in Columbia, South Carolina.


Our room block at La Fonda on the Plaza has closed. Please contact AAJ Education at if you still need to book your hotel room.

La Fonda on the Plaza
110 E. San Francisco Street
Santa Fe, NM 87501
Tel: (505) 982-5511


Who should attend:

This seminar is open to AAJ Members (Regular, Life, Sustaining, President’s Club, and Leaders Forum). AAJ Paralegal Affiliates may attend this seminar.

Program Location:

La Fonda on the Plaza
100 E. San Francisco Street
Santa Fe, NM 87501
Tel: (505) 982-5511


Call us. We'll provide you with names and phone numbers of previous attendees of AAJ Education programs who will be pleased to answer your questions. Or, if you prefer to speak with a course advisor or faculty member, we will arrange that as well. Call 800.622.1791 or 202.965.3500, extension 8612.

MCLE/NCA Requirements:

AAJ has filed for MCLE credit in the appropriate jurisdictions.  Registered participants can receive approximately 10* CLE credits depending on the jurisdiction and will be applied to your participation in AAJ’s professional recognition programs. AAJ Education programs are routinely accredited by states requiring continuing legal education. CLE questions may be addressed by reading our FAQ or calling the CLE Assistant at 800-622-1791.​

Click here to learn more about AAJ's Professional Recognition Programs, Achievement Recognition Program (ARP) and Advanced Studies in Trial Advocacy (ASTA), or call 800-622-1791 or 202-965-3500, ext. 9584. The Achievement Recognition Program (ARP) provides Advocate, Fellow, and Diplomate recognition to AAJ members. To gain ARP credits, submit a certificate of attendance for every seminar, college, and convention you attend.

* Number of credits may vary depending on calculation method used by individual state accreditation agencies. AAJ is a State Bar of California MCLE-approved provider.

Special Assistance:

AAJ Education will make every effort to ensure that its meetings are held in facilities that are fully accessible to persons with mobility disabilities. If you plan to attend our program and need special facilities or assistance relating to a disability, please call 800-622-1791 or 202-965-3500, ext. 8612. 

Cancellation Policy:

Cancellations received in writing on or before May 2, 2019 will result in a refund less a 10% administrative charge. Cancellations received in writing May 3-7, 2019 will result in a voucher for the entire registration fee, which may be applied toward any AAJ Education college, seminar, or webinar held within one calendar year of the date of issue. Requests for refunds or vouchers received 48 hours of the program will not be honored. AAJ is not responsible for any room cancellation fees or other travel fees which result from your cancellation. Cancellation requests must be made in writing. Fax or email your cancellation letter to the registrar at 202-625-7084 or

Contribute to the AAJ Education Fund:

Please consider a donation to the AAJ Education Fund 501(c)(3). Contributions support educational programs and activities to preserve and protect the civil justice system. Learn more>>

Terms and Conditions:

The American Association for Justice reserves the right to, in its sole discretion, refuse entrance to the event and/or remove any individual from the event whose behavior is disruptive and/or is not consistent with the character and purpose of the event. All American Association for Justice badges are the property of the American Association for Justice and must be returned upon request.

By registering for this AAJ Education program, you agree to receive electronic, written, and telephonic communication from AAJ staff regarding the program and to have your name, firm, city, and state included on the participant and exhibitor/sponsor roster.  AAJ may also need to contact you to service your membership record or to provide you with information about your membership, products and services, and advocacy and legislative updates.  By providing your contact information, including phone number, fax number, and email address, you consent and give permission for AAJ to contact you by any of those means, which may include calls to your mobile phone, faxes, or emails. You may contact AAJ at any time to change your preferences.

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