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Advanced Deposition Tactics

Credits Available
Credit Status Total
Alaska CLE Reciprocity 6 Total
Alabama CLE Approved 6 Total
Arkansas CLE Approved 6 Total
Arizona CLE Approved 6 Total
California CLE Approved 6 Total
Colorado CLE Approved 7 Total
Connecticut CLE Approved 6 Total
Delaware CLE Approved 6 Total
Florida CLE Approved 7 Total
Georgia CLE Approved 6 Total
Hawaii CLE Approved 6 Total
Iowa CLE Approved 6 Total
Idaho CLE Approved 6 Total
Illinois CLE Approved 6 Total
Indiana CLE Approved 6 Total
Kansas CLE Approved 7 Total
Kentucky CLE Approved 6 Total
Maine CLE Approved 6 Total
Minnesota CLE Approved 6 Total
Missouri CLE Approved 6 Total
Northern Mariana Islands CLE Approved 6 Total
Mississippi CLE Approved 6 Total
Montana CLE Approved 6 Total
North Carolina CLE Approved 6 Total
North Dakota CLE Approved 6 Total
Nebraska CLE Approved 6 Total
New Hampshire CLE Approved 6 Total
New Jersey CLE Approved 7.2 Total
New Mexico CLE Approved 6 Total
Nevada CLE Approved 6 Total
New York CLE Approved 7 Total
Ohio CLE Approved 6 Total
Oklahoma CLE Approved 7 Total
Oregon CLE Approved 6 Total
Pennsylvania CLE Approved 6 Total
Rhode Island CLE Upon Request 6 Total
South Carolina CLE Approved 6 Total
Tennessee CLE Approved 6 Total
Texas CLE Approved 3 Total
Utah CLE Approved 6 Total
Virginia CLE Approved 6 Total
Vermont CLE Approved 6 Total
Washington CLE Approved 6 Total
Wisconsin CLE Approved 7 Total
West Virginia CLE Approved 7.2 Total
Wyoming CLE Approved 6 Total
OnDemand
6 hours 2 minutes
Gerald Connor
James Susag
Jan Berlage
With Gerald A. Connor from Margolis Edelstein + 2 others
Recorded January 23, 2026.
Product ID 101496

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Course Includes
$389

OnDemand Video

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Course Book Download

Overview

Take Your Skills to the Next Level

Make your depositions more fruitful! Whether you're trying to ascertain facts, size up a witness, or capture testimony that can be used to impeach, our seasoned faculty will reveal time-tested strategies for achieving your goals. You will also learn creative techniques for defending depositions. Get the tactics you need to obtain killer testimony or help your witness withstand aggressive questioning by opposing counsel - register today!

  • Learn where to go to find even more information or dirt on the deponent.
  • Apply creative questioning styles and techniques to get the testimony you want.
  • Avoid and undermine answers that are harmful to your client's case.
  • Find out how to steer expert witness testimony with precision.
  • Tailor your strategy: learn techniques that work with different types of deponents.
  • Get tips for dealing with opposing counsel that is being overly obstructive or aggressive.
  • Find out how to best prepare witnesses for the trick questions.

Abbreviated Agenda

  1. Preparing for Depositions: Creative Insights
  2. Deposition Questioning Strategies and Tactics
  3. The Art of Expert Witness Depositions
  4. Dealing With Different Types of Witnesses
  5. Rambo Depositions: How to Deal With Difficult Opposing Counsel
  6. Defending Depositions: Tips From a Seasoned Litigator
  7. Mastering the Remote Deposition
  8. Deposition Ethics

Related Topics

Product ID 101496

Credit Details

Credits Available
Credit Status Total
Alaska CLE Reciprocity 6 Total
Alabama CLE Approved 6 Total
Arkansas CLE Approved 6 Total
Arizona CLE Approved 6 Total
California CLE Approved 6 Total
Colorado CLE Approved 7 Total
Connecticut CLE Approved 6 Total
Delaware CLE Approved 6 Total
Florida CLE Approved 7 Total
Georgia CLE Approved 6 Total
Hawaii CLE Approved 6 Total
Iowa CLE Approved 6 Total
Idaho CLE Approved 6 Total
Illinois CLE Approved 6 Total
Indiana CLE Approved 6 Total
Kansas CLE Approved 7 Total
Kentucky CLE Approved 6 Total
Maine CLE Approved 6 Total
Minnesota CLE Approved 6 Total
Missouri CLE Approved 6 Total
Northern Mariana Islands CLE Approved 6 Total
Mississippi CLE Approved 6 Total
Montana CLE Approved 6 Total
North Carolina CLE Approved 6 Total
North Dakota CLE Approved 6 Total
Nebraska CLE Approved 6 Total
New Hampshire CLE Approved 6 Total
New Jersey CLE Approved 7.2 Total
New Mexico CLE Approved 6 Total
Nevada CLE Approved 6 Total
New York CLE Approved 7 Total
Ohio CLE Approved 6 Total
Oklahoma CLE Approved 7 Total
Oregon CLE Approved 6 Total
Pennsylvania CLE Approved 6 Total
Rhode Island CLE Upon Request 6 Total
South Carolina CLE Approved 6 Total
Tennessee CLE Approved 6 Total
Texas CLE Approved 3 Total
Utah CLE Approved 6 Total
Virginia CLE Approved 6 Total
Vermont CLE Approved 6 Total
Washington CLE Approved 6 Total
Wisconsin CLE Approved 7 Total
West Virginia CLE Approved 7.2 Total
Wyoming CLE Approved 6 Total
Select Jurisdiction
CLE

Agenda

All times are shown in

  1. Preparing for Depositions: Creative Insights

    1. Finding a Wealth of Information on the Deponent
    2. Outline Pointers
    3. Anticipating Evidentiary Issues
    4. Potential Problem Areas and How to Handle Them
    5. Controlling the Environment

  2. Deposition Questioning Strategies and Tactics

    1. Style of Questioning, Form of Questions
    2. Organizing Your Questioning - the Funnel Technique
    3. Boxing-In and Exhaustion Strategies
    4. Timeline Techniques
    5. Preserving Your Strongest Questions
    6. Successfully Handling Objections
    7. Eliciting and Cementing Helpful Answers
    8. Fertile Ground for Useful Admissions
    9. Undermining Harmful Answers

  3. The Art of Expert Witness Depositions

    1. The Report
    2. Finding Impeachment Material
    3. Key Techniques for Taking Expert Depositions
    4. Killer Deposition Questions for Expert Witnesses
    5. Tips for Defending Expert Depositions

  4. Dealing With Different Types of Witnesses

    1. Forgetful, Confused, or Evasive Witnesses
    2. Deponents Who Respond With Vague Answers
    3. The Liar
    4. Tactical Approaches to Inconsistent Statements
    5. Deponents Who Talk Too Much
    6. Uncooperative Witnesses
    7. Hostile or Arguing Witnesses
    8. The Child Witness
    9. Deponents With Mental Health Conditions or Diminished Capacity

  5. Rambo Depositions: How to Deal With Difficult Opposing Counsel

  6. Defending Depositions: Tips From a Seasoned Litigator

    1. Things You Should Always Tell Deponents
    2. Preparing Deponents for Tricky and Difficult Questions
    3. Leveraging Objections
    4. Intervention: Opportunities, Timing, and Pointers
    5. Going Off the Record
    6. Instructing the Witness

  7. Mastering the Remote Deposition

  8. Deposition Ethics

    1. Preparing vs. Coaching a Witness
    2. Candor: When a Client or Witness Lies
    3. Keeping it Civil
    4. Collecting Information About Deponents: Ethical Issues
    5. Representing the Non-Party Witness
    6. Prohibited Communications and Solicitations
    7. Ethics Concerns With Remote Depositions

Who Should Attend

This program is designed for attorneys.

Speakers

Gerald A Connor
Gerald A.
Connor
Margolis Edelstein
James M Susag
James M.
Susag
Larkin Hoffman Daly & Lindgren Ltd.
Jan I Berlage
Jan I.
Berlage
Gohn Hankey & Berlage LLP
Speaker bio
Gerald A Connor

Gerald A. Connor

Margolis Edelstein
Gerald Connor

is a partner and trial attorney in the Scranton, Pennsylvania office of Margolis Edelstein, a full service multi-state litigation provider to the insurance industry, major corporations and governmental entities. He focuses his practice on casualty litigation, ranging from automobile and general liability claims to products liability, construction litigation and workers' compensation claims. Mr. Connor also has extensive experience in commercial litigation, intellectual property issues, municipal claims, and employment law. He has handled dozens of trials, administrative hearings and arbitrations to verdict, and is active at the appellate level in both state and federal court. Mr. Connor is a member of the Lackawanna County and Pennsylvania bar associations. He earned his B.A. degree from the University of Pennsylvania and his J.D. degree from Widener University School of Law.

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Speaker bio
James M Susag

James M. Susag

Larkin Hoffman Daly & Lindgren Ltd.
James Susag

is a seasoned trial attorney with a focus on franchise and dealer disputes, real estate, and complex commercial matters. He has been the lead attorney in over 100 trials and arbitrations in state and federal courts across the country, and in domestic and international arbitration forums. Mr. Susag has the unique perspective of a trial lawyer who has also managed complex litigation and developed strategic legal plans as in-house counsel. Clients appreciate his boardroom-to-courtroom experience in crafting resolutions for their business disputes. Mr. Susag is admitted to practice in state and federal courts in Minnesota, Washington and Wisconsin, as well as the U.S. Court of Appeals for the Seventh, Fourth and Eighth circuits. He earned his B.A. degree, summa cum laude, from the University of St. Thomas and his J.D. degree, summa cum laude, from William Mitchell College of Law.

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Speaker bio
Jan I Berlage

Jan I. Berlage

Gohn Hankey & Berlage LLP
Jan Berlage

is a partner with Gohn Hankey & Berlage LLP. His practice focuses on general business litigation, ranging from commercial disputes to bankruptcy to intellectual property. Mr. Berlage has extensive experience in trials, arbitrations, mediations, and administrative hearings, including arguments before the Maryland Court of Appeals and the U.S. Court of Appeals for the Third and Fourth circuits. He has secured major jury verdicts and large settlements for both businesses and individuals, as well as successfully defended against multi-million dollar claims in both state and federal court. Prior to private practice, Mr. Berlage served as law clerk to the Honorable E. Stephen Derby, U.S. Bankruptcy Court for the District of Maryland. He has taught pretrial litigation practice at the University of Maryland School of Law, and served on the Board of Governors for the Maryland State Bar Association and the U.S. Commission on Civil Rights, Maryland State Action Committee. Mr. Berlage is a fellow of both the American and Maryland State bar associations, presents regularly at CLE courses, and has been the chair of numerous committees at both the national and state level. He earned his B.A. degree, with honors, from Wesleyan University; his J.D. degree from the University of Virginia School of Law, where he served as executive editor of The Journal of Law & Politics; and is a member of Phi Beta Kappa.

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