AAJ Press

Related Resource

This title is also available as an e-book! Choose your format to learn from the master of combating deposition obstruction. Order as E-Book

Deposition Obstruction Cover dart breaking through a stone wall to hit a bulls eye
AAJ Press

Deposition Obstruction: Breaking Through

By Mark R. Kosieradzki
CreatedJan 17, 2019
Delivery method: Shipped

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.

You do not need to be an AAJ member to purchase this book.  Nonmembers will need to create an account with shipping and contact information to purchase.


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 The Lanier Law Firm Houston, TX

Table of Contents

  • 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