Litigation & Appeals

4.53

Deposing and Cross-Examining Experts, Difficult, and Special Witnesses

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
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 6 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 3 minutes
James Andreen
Jena Emory
Mark West
James Susag
With James R. Andreen from Erstad & Riemer PA + 3 others
Recorded March 23, 2026.
Product ID 101611

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Overview

Tailor Your Strategy to the Witness in Question

Approaching depositions and cross-examination with a "one-size-fits-all" approach will quickly lead to trouble. Knowing the witness types and how to control them are crucial to getting the answers you need. In this program, seasoned attorneys will show you tailored strategies to use with key types of witnesses. From experts to hostile witnesses and more, gain the insights you need to damage credibility and steer testimony with precision. Add to your arsenal - register today!

  • Gain practical tips for deposing and cross-examining experts.
  • Get control over tough witnesses - including the explaining witness, the turncoat, the sympathetic witness, and more.
  • Discover how to tactfully examine children and other vulnerable or special witnesses.
  • Dig into the unique nuances of 30(b)(6) depositions.
  • Find out how to deal with opposing counsel who utilize obstructionist deposition tactics.

Abbreviated Agenda

  1. Golden Rules (and Sins) of Depositions & Cross-Examination
  2. Expert Witnesses Deposition and Cross-Examination Tactics
  3. Tactfully Examining Children and Other Special Witnesses
  4. Tips for Cross-Examining Specific Types of Experts
  5. Controlling and Impeaching Difficult Witnesses
  6. Deposing Corporate and Government Representatives
  7. Dirty Deposition Tactics - Handling Obstructionist Conduct
  8. Legal Ethics - Know When the Line Has Been Crossed

Related Topics

Product ID 101611

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
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 6 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. Golden Rules (and Sins) of Depositions & Cross-Examination

  2. Expert Witnesses Deposition and Cross-Examination Tactics

    1. Investigating the Expert's Experience
    2. Reviewing the Expert's File and Report
    3. Question Construction and Sequence
    4. Taking the Expert's Deposition: Getting Started
    5. Fully Uncovering the Expert's Opinions and Bases for Them
    6. Eliciting Areas of Agreement
    7. Boxing in the Expert and Establishing Grounds for Impeachment
    8. Setting Up a Daubert Challenge
    9. Staying in Control of the Expert Witness
    10. Undermining the Expert's Opinions at Trial

  3. Tactfully Examining Children and Other Special Witnesses

    1. Capacity and Witness Accommodations
    2. Making a Child Witness Feel Comfortable
    3. How to Interview Children at Different Ages
    4. Formulating Questions for the Child Witness
    5. Challenging Children's Testimony
    6. Cross-Examining Witnesses with Autism and Other Disorders
    7. Handling Witnesses Who Lack of Fluency in English
    8. Witnesses of Different Cultural, Educational, or Other Backgrounds

  4. Tips for Cross-Examining Specific Types of Experts

    1. The Medical Expert
    2. The Scientific/Technical Expert
    3. Economic and Vocational Experts

  5. Controlling and Impeaching Difficult Witnesses

    1. The Arguing Witness
    2. The Runaway/Explaining Witness
    3. The Silent or Evasive Witness
    4. The Liar
    5. The Mistaken or Forgetful Witness
    6. The Sympathetic or Crying Witness
    7. The Surprise Witness
    8. The Turncoat
    9. The Character Witness
    10. The Eyewitness

  6. Deposing Corporate and Government Representatives

    1. 30(b)(6) Depositions - Rule and Case Law Updates
    2. Notice of Deposition
    3. Witness Selection
    4. Inquiries Into Areas Not Within the Scope of the Notice
    5. Practical Tips for Deposing Corporate Representatives
    6. Tips for Examining the Government Representative

  7. Dirty Deposition Tactics - Handling Obstructionist Conduct

    1. Coaching the Witness
    2. Instructing the Witness Not to Answer
    3. Excessive, Vague, or Baseless Objections
    4. Interjections and Interruptions
    5. When and How to Bring Matters to the Judge's Attention

  8. Legal Ethics - Know When the Line Has Been Crossed

    1. Professionalism and Civility
    2. Witness Preparation vs. Coaching
    3. Candor Toward the Tribunal
    4. Discrediting the Truthful Witness
    5. Preserving Confidentiality and Privilege

Who Should Attend

This program is designed for attorneys.

Speakers

James R Andreen
James R.
Andreen
Erstad & Riemer PA
Jena G Emory
Jena G.
Emory
Taft Stettinius & Hollister LLP
Mark West
Mark
West
Law Offices of Mark West
James M Susag
James M.
Susag
Larkin Hoffman Daly & Lindgren Ltd.
Speaker bio
James R Andreen

James R. Andreen

Erstad & Riemer PA
James Andreen

is a shareholder for the law firm for Erstad & Riemer PA, where he is a trial and appellate lawyer, mainly in the areas of employment and civil rights. He is a member of the Federal, Hennepin County and Minnesota State bar associations, as well as the Minnesota Defense Lawyers Association. Mr. Andreen earned his B.A. degree from the University of Minnesota and his J.D. degree, cum laude, from Hamline University School of Law.

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Speaker bio
Jena G Emory

Jena G. Emory

Taft Stettinius & Hollister LLP
Jena Emory

is an associate in Taft Stettinius & Hollister LLP's Commercial, Class Action and Product Liability Litigation practices, with a specialization in insurance coverage. She brings extensive experience and a proven track record in handling complex legal matters, drafting legal documents, and representing clients in complex insurance coverage and general liability cases. Additionally, Ms. Emory has experience managing cases solo in both the Superior and Magistrate courts and drafting motions including complex federal jurisdiction. Jena currently serves as the programming manager for the Young Lawyers Division and co-chair of the Young Advocates Committee for the Litigation Section of the American Bar Association. She is also the former Newsletter co-editor for the Young Lawyers Division of the State Bar of Georgia, where she played a crucial role in distributing important legal updates and supporting the professional growth of fellow attorneys. Additionally, Ms. Emory is a 2020 graduate of the State Bar of Georgia's YLD Leadership Academy. She earned her J.D. degree from the University of Georgia School of Law and her B.S. degree, magna cum laude, from the University of South Carolina.

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Speaker bio
Mark West

Mark West

Law Offices of Mark West
Mark West

is a sole practitioner in San Gabriel, where he practices in plaintiff personal injury and wrongful death, products liability law, medical malpractice, and business civil litigation. He has published several articles and frequently lectures. Mr. West is admitted to practice in the Northern, Central and Southern U.S. District Courts in California; Ninth Circuit Court of Appeals; and Supreme Court of the United States. He has also been admitted pro hac vice in the state and U.S. District Court for Nevada, and the U.S. District Court for Minnesota. Mr. West is a member of the American and Los Angeles County bar associations, State Bar of California, Consumer Attorneys Association of Los Angeles, Consumer Attorneys of California (past legislative district coordinator), and American Trial Lawyers Association. He earned his B.S. degree from New Hampshire College (now Southern New Hampshire University) and his J.D. degree from Southwestern 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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