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Both the novice and experienced will benefit from Sybil’s perspective on the art and science of depositions. She will not present dictates, but will illuminate tactics and styles, to help you fashion or improve your own approach. She will work with you to develop a deposition persona that is uniquely personal and unquestionably successful!
AGENDA
9:00 A.M. Preparing your witness to succeed
“Best practices” for preparing your witness include the use
of documents during preparation and the latest research to
help your witness feel comfortable and perform at his or
her best.
Drafting and using outlines
While you never want to be tied to your outline, advance
preparation allows you the flexibility to move beyond the
outline in a deposition. We’ll review several outline
templates to identify the styles that will work best in different circumstances.
10:30 A.M. Coffee Break
10:45 A.M. Taking and defending depositions
Whether conducting a discovery deposition, a trial deposition,
a hybrid or defending your own witness, the fundamentals
are crucial. Beyond those basics, though, Sybil provides
tips and tricks to elevate your performance.
Effective objections
When defending a deposition, the objection is your primary
tool. This section covers everything — from teaching your
witness about depositions to effectively using them to
preserve your record.
12:15 P.M. Lunch (on your own)
1:15 P.M. Expert depositions The expert has likely been deposed before—explore special
considerations for expert depositions including how to set up
a Daubert motion, your trial cross-examination, or even
increase your chances of settlement.
Identifying your deposition style
Playing to your own strengths will help you achieve your
deposition objectives (and feel comfortable while doing so).
Identify your own deposition style by examining a showcase
of various, successful models.
2:45 P.M. Refreshment Break
3:00 P.M. Deposition technology
The court reporter is an officer of the court. Your ethical
interaction with the reporter as well as the proper use of
technology, including video, Realtime, and electronic exhibits
increase your likelihood of a successful deposition.
Ethical pitfalls to avoid
When there is a transcript, there is room for error. This
section reviews recent case law providing deposition
guidance and offers advice for avoiding ethical missteps.
4:30 P.M. Adjourn