Deposition Techniques: Strategies, Tactics, and Skills

David B. Markowitz

Format: Audiobook
Condition: New
Sale price$225.00

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Depositions can make or break your case, and this is your chance to learn from a master. This is an excellent Deposition CLE for new lawyers and experienced lawyers.

For over thirty years, David Markowitz has been studying deposition and trial techniques and has presented dozens of seminars to improve the skills of practicing attorneys. One of the nation's leading corporate litigators, he is widely recognized as a leading authorities in deposition techniques. In this deposition CLE, David shares important goals to accomplish in depositions. Learn the value of question structure and how to deal with evasive and incomplete answers. This deposition CLE video 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 Deposition CLE 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


CD: 366 minutes; 6 discs; 1st edition (2010); ISBN: 978-1934833315
DVD: 366 minutes; 4 discs; 1st edition (2010); ISBN: 978-1934833278
Publisher: Trial Guides, LLC

DVD: Disc 1 [105:25]

  1. Introduction [0:00]
  2. Deposition Goals –Part A
  3. Deposition Goals –Part A
  4. Deposition Goals –Part A
  5. Deposition Goals –Part A
  6. Deposition Goals –Part A
  7. Deposition Goals –Part A
  8. Deposition Goals –Part A
  9. Deposition Goals –Part A
  10. Deposition Goals –Part A
  11. Deposition Goals –Part B
  12. Deposition Goals –Part B
  13. Deposition Goals –Part B
  14. Deposition Goals –Part B
  15. Deposition Goals –Part B
  16. Deposition Goals –Part B
  17. Deposition Goals –Part C
  18. How to Ask Questions –Part A
  19. How to Ask Questions –Part A
  20. How to Ask Questions –Part A
  21. How to Ask Questions –Part A
  22. How to Ask Questions –Part A
  23. How to Ask Questions –Part A

DVD: Disc 2 [67:38]

  1. How to Ask Questions –Part B
  2. How to Ask Questions –Part C
  3. How to Ask Questions –Part D
  4. How to Ask Questions –Part D
  5. What to Ask –Part A
  6. What to Ask –Part A
  7. What to Ask –Part B
  8. What to Ask –Part B
  9. What to Ask –Part B
  10. What to Ask –Part B
  11. What to Ask –Part B
  12. What to Ask –Part B
  13. What to Ask –Part C
  14. What to Ask –Part D
  15. What to Ask –Part E

DVD: Disc 3 [92:56]

  1. What to Ask –Part F
  2. What to Ask –Part G
  3. What to Ask –Part H
  4. Dealing with the Lying Witness –Part A
  5. Dealing with the Lying Witness –Part A
  6. Dealing with the Lying Witness –Part B
  7. Dealing with the Lying Witness –Part D
  8. Dealing with the Lying Witness –Part E
  9. A Witness Who Knows Too Little –Part A
  10. A Witness Who Knows Too Little –Part B
  11. A Witness Who Knows Too Little –Part C
  12. A Witness Who Knows Too Little –Part C
  13. A Witness Who Knows Too Little –Part C
  14. A Witness Who Knows Too Little –Part C
  15. Getting It All –Part A
  16. Getting It All –Part A
  17. Getting It All –Part B
  18. Getting It All –Part C
  19. When to Stop Asking Questions –Part A
  20. When to Stop Asking Questions –Part B
  21. Defending Depositions –Part A
  22. Defending Depositions –Part A

DVD: Disc 4 [100:38]

  1. Defending Deposition –Part A
  2. Defending Deposition –Part B
  3. Defending Deposition –Part B
  4. Defending Deposition –Part B
  5. Defending Deposition –Part B
  6. Defending Deposition –Part B
  7. Defending Deposition –Part B
  8. Defending Deposition –Part B
  9. Defending Deposition –Part B
  10. Defending Deposition –Part B
  11. Defending Deposition –Part B
  12. Defending Deposition –Part B
  13. Defending Deposition –Part B
  14. Defending Deposition –Part B
  15. Defending Deposition –Part C
  16. Defending Deposition –Part C
  17. Defending Deposition –Part C
  18. Defending Deposition –Part C
  19. Defending Deposition –Part C
  20. Defending Deposition –Part C
  21. Defending Deposition –Part C
  22. Defending Deposition –Part C
  23. Defending Deposition –Part C
  24. Defending Deposition –Part C
  25. Defending Deposition –Part C

Total running time: 6 hours, 6 minutes

What Legal Leaders Are Saying

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