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Deposition Techniques (CD)

Strategies, Tactics, and Skills

David B. Markowitz

Media: 6 CDs; 1st edition (2010)

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Trial Guides Podcast

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Description

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

For more than 20 years, David Markowitz has been studying deposition and trial techniques and has presented dozens of seminars to improve the skills of practicing attorneys. David will share with you important goals to accomplish, including avoiding undesired results. Learn the value of question structure and how to deal with evasive and incomplete answers. The most important questions and techniques the best lawyers use will be covered, as will a key component of any deposition—knowing when to stop asking questions.

Through David’s keen ability to communicate and persuade, he will demonstrate powerful, 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 lion is an opportunity not to be missed.

Important Deposition Goals to Accomplish

  • Determine goals and objectives
  • Accomplishing desire results
  • Avoiding undesired results

How to Ask Questions Effetively

  • Correct question structure
  • Dealing with evasive and incomplete answers

What to Ask

  • Formulating tough and thorough questions
  • Asking the most important questions
  • Effective ordering of questions
  • Big questions—if, how, and when to ask them
  • Techniques the best lawyers use

Dealing with Problem Witnesses

  • The lying witness
  • The witness who doesn’t remember
  • The exaggerating witness

When to Stop Asking Questions

Style and Demeanor

Defending Depostions

  • Goals
  • Pre-deposition 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 objections
  • Dealing with instrutions 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

Reviews

  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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