Deposition Techniques: Strategies, Tactics, and Skills

David B. Markowitz

Format: Audiobook
Condition: New
Sale price$225.00

Please Note: If you choose the Audiobook option, you can access it through the Trial Guides App for Lawyers button on your account page.

Click here for further information on Deposition Audiobooks

Learn Deposition Techniques from a Leading Litigator

Depositions can make or break your case. This educational video is your chance to learn how to get the answers you need, from a master. This is an excellent introductory Deposition Technique video for newer lawyers learning basic deposition methods. It also helps experienced lawyers, who want to improve their case outcomes, by changing how they depose parties, corporate representatives and expert witnesses.

David Markowitz is long recognized by Chambers USA as a top commercial litigator, consistently named in Best Lawyers in America, and is a Fellow of the American College of Trial Lawyers. Markowitz is nationally recognized as a leading authority in deposition strategy and methods. He is co-author ofThe Deposition Handbook, 6th Edition - the definitive book on the depositions. For over 30 years, the treatise has been used by many of the world's largest law firms to teach the art of taking and defending depositions.

In this video, Markowitz shares important goals for legal discovery. He discusses the techniques used by leading litigators, including the most important questions you should ask. It also covers 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 both the best methods in taking the deposition of an opposing witness, as well as the best ways to defend depositions. He also addresses how to effectively use deposition testimony at trial.

This Deposition video covers the following topics:

  • Determining goals and objectives
  • Accomplishing desired results for your litigation
  • How to ask questions effectively
  • Using the correct question structure
  • Dealing with evasive and incomplete answers by deponents
  • Formulating tough and thorough questions
  • Effectively ordering questions
  • Big questions—if, how, and when to ask them
  • How to deal with problematic witnesses such as lying witnesses, witnesses who can’t remember, and witnesses who exaggerate.
  • Style and demeanor
  • How you can prepare your witness
  • How to conduct your witnesses preparation meetings
  • Teaching your client how to be a terrific witness
  • Protecting your client—including proper objections
  • Overcoming objections to your questions
  • Dealing with instructions not to answer
  • How to work effectively with the court reporter and videographer

Whether you are new to trial practice or want to improve your case outcomes, don't miss this program.

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

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.