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Deposition Techniques (CD)

Strategies, Tactics, and Skills

David B. Markowitz

Media: 6 CDs; 1st edition (2010)

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Depositions can make or break your case, and this is your chance to learn from a master.

For over twenty years, David Markowitz has been studying deposition and trial techniques and has presented dozens of seminars to improve the skills of practicing attorneys. In this lecture, David shares important goals to accomplish in depositions. Learn the value of question structure and how to deal with evasive and incomplete answers. This lecture will also cover the most important questions and techniques the best lawyers use, plus a key component of any deposition: knowing when to stop asking questions.

David demonstrates powerful and practical methods for getting the most out of your depositions, including the best ways to defend depositions and effectively use depositions at trial. Whether you are new to trial practice or want to refresh your deposition skills, this presentation by a litigation icon is an opportunity not to be missed.

This lecture tackles the following topics:

  • Determining goals and objectives
  • Accomplishing desired results
  • How to ask questions effectively
  • Using the correct question structure
  • Dealing with evasive and incomplete answers
  • Formulating tough and thorough questions
  • Effectively ordering questions
  • Big questions—if, how, and when to ask them
  • Dealing with problem witnesses (lying witnesses, witnesses who can’t remember, and witnesses who exaggerate)
  • Style and Demeanor
  • Defending depositions
  • Predeposition meetings with witnesses
  • Teaching your client how to be a terrific deposition witness
  • Protecting your client during depositions—including proper objections
  • Overcoming objections
  • Dealing with instructions not to answer

This title is part of the iWin® series of educational media by Trial Guides™.

Track List

CD 1 [63:30]

1. Introduction [7:01]
2. Deposition Goals –Part A [5:37]
3. Deposition Goals –Part A [6:16]
4. Deposition Goals –Part A [5:39]
5. Deposition Goals –Part A [3:07]
6. Deposition Goals –Part A [4:49]
7. Deposition Goals –Part A [3:04]
8. Deposition Goals –Part A [4:15]
9. Deposition Goals –Part A [2:30]
10. Deposition Goals –Part A [4:13]
11. Deposition Goals –Part B [3:06]
12. Deposition Goals –Part B [5:27]
13. Deposition Goals –Part B [4:07]
14. Deposition Goals –Part B [4:19]

CD 2 [64:14]

1. Deposition Goals –Part B [2:58]
2. Deposition Goals –Part B [5:08]
3. Deposition Goals –Part C [2:39]
4. How to Ask Questions –Part A [3:59]
5. How to Ask Questions –Part A [4:05]
6. How to Ask Questions –Part A [3:45]
7. How to Ask Questions –Part A [5:33]
8. How to Ask Questions –Part A [6:07]
9. How to Ask Questions –Part A [7:28]
10. How to Ask Questions –Part B [3:48]
11. How to Ask Questions –Part C [3:07]
12. How to Ask Questions –Part D [3:49]
13. How to Ask Questions –Part D [2:12]
14. What to Ask –Part A [9:36]

CD 3 [63:59]

1. What to Ask –Part A [5:32]
2. What to Ask –Part B [4:00]
3. What to Ask –Part B [3:42]
4. What to Ask –Part B [3:58]
5. What to Ask –Part B [3:02]
6. What to Ask –Part B [5:56]
7. What to Ask –Part B [1:40]
8. What to Ask –Part C [4:33]
9. What to Ask –Part D [5:17]
10. What to Ask –Part E [6:58]
11. What to Ask –Part F [2:52]
12. What to Ask –Part G [5:32]
13. What to Ask –Part H [6:57]
14. Dealing with the Lying Witness –Part A [4:35]

CD 4 [56:54]

1. Dealing with the Lying Witness –Part A [3:51]
2. Dealing with the Lying Witness –Part B [5:30]
3. Dealing with the Lying Witness –Part D [2:37]
4. Dealing with the Lying Witness –Part E [4:00]
5. A Witness Who Knows Too Little –Part A [4:58]
6. A Witness Who Knows Too Little –Part B [3:29]
7. A Witness Who Knows Too Little –Part C [4:24]
8. A Witness Who Knows Too Little –Part C [4:17]
9. A Witness Who Knows Too Little –Part C [4:29]
10. A Witness Who Knows Too Little –Part C [4:01]
11. Getting It All –Part A [2:20]
12. Getting It All –Part A [4:50]
13. Getting It All –Part B [2:35]
14. Getting It All –Part C [5:33]

CD 5 [60:10]

1. When to Stop Asking Questions –Part A [4:30]
2. When to Stop Asking Questions –Part B [3:55]
3. Defending Depositions –Part A [4:11]
4. Defending Depositions –Part A [3:13]
5. Defending Deposition –Part A [4:36]
6. Defending Deposition –Part B [4:06]
7. Defending Deposition –Part B [3:49]
8. Defending Deposition –Part B [2:52]
9. Defending Deposition –Part B [3:26]
10. Defending Deposition –Part B [4:40]
11. Defending Deposition –Part B [2:17]
12. Defending Deposition –Part B [3:01]
13. Defending Deposition –Part B [5:01]
14. Defending Deposition –Part B [2:13]
15. Defending Deposition –Part B [4:38]
16. Defending Deposition –Part B [3:42]

CD 6 [56:17]

1. Defending Deposition –Part B [4:20]
2. Defending Deposition –Part B [6:31]
3. Defending Deposition –Part C [4:16]
4. Defending Deposition –Part C [6:56]
5. Defending Deposition –Part C [3:06]
6. Defending Deposition –Part C [2:44]
7. Defending Deposition –Part C [3:32]
8. Defending Deposition –Part C [2:50]
9. Defending Deposition –Part C [2:49]
10. Defending Deposition –Part C [5:36]
11. Defending Deposition –Part C [4:54]
12. Defending Deposition –Part C [5:51]
13. Defending Deposition –Part C [2:52]

Total running time: 6 hours, 5 minutes


  1. We spend most of own time educating ourselves on how to conduct trials, even though many of our cases will settle with well done discovery. This DVD is key to successful discovery. Markowitz takes all the things you may or may not remember to do in deposition and puts them together methodically. This DVD is phenomenal.
    —Deryl Edwards Jr., Esq.

  2. Viewing these DVDs is by far the easiest, quickest way I know to learn the most about deposition practice. Presented by David Markowitz, one of the nation’s most knowledgeable experts on depositions, the program begins with a discussion of the pros and cons of taking a deposition, moves on to a thoughtful consideration of deciding upon your objectives, offers an array of questioning techniques designed to achieve your objectives, gives practical advice on how to deal with the difficult opponent, explains the ways in which depositions can be used at trial, and ends with sound advice on preparing the witness to testify and how to protect him at the deposition. It is no exaggeration to say that it could take years of taking and defending depositions to learn what is so beautifully and entertainingly distilled here in the space of six hours.
    —Dennis R. Suplee, Esq.

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