Deposition Control

Becoming the Authority on Controlling the Conversation

Whether you are seeking information, an admission, or defending your client, your control of a deposition is critical to case success.
Sybil Dunlop summons her varied experiences as a successful trial lawyer and marries them with her remarkable teaching talent
and excitement for the practice of law to deliver a unique experience.

Both the novice and experienced will benefit from Sybil’s perspective on the art and science of depositions. She will not present
dictates, but will illuminate tactics and styles, to help you fashion or improve your own approach. She will work with you to develop
a deposition persona that is uniquely personal and unquestionably successful!

• Preparing your witness to succeed;

• Drafting and using outlines;

• Taking and defending depositions;

• Effective objections;

• Expert depositions;

• Identifying your deposition style;

• Deposition technology; and

• Ethical pitfalls to avoid.

Program Agenda & Detail

6 Hours Including 1 Ethics

[Part I: 1 Hour, 27 Minutes]

Preparing your witness to succeed

“Best practices” for preparing your witness include the use of documents during preparation and the latest research to help your
witness feel comfortable and perform at his or her best.

Drafting and using outlines
While you never want to be tied to your outline, advance preparation allows you the flexibility to move beyond the outline in a deposition.
We’ll review several outline templates to identify the styles that will work best in different circumstances.

[Part II: 1 Hour, 29 Minutes]

Taking and defending depositions

Whether conducting a discovery deposition, a trial deposition, a hybrid or defending your own witness, the fundamentals are crucial.
Beyond those basics, though, Sybil provides tips and tricks to elevate your performance.

Effective objections
When defending a deposition, the objection is your primary tool. This section covers everything—from teaching your witness about
depositions to effectively using them to preserve your record.

[Part III: 1 Hour, 29 Minutes]

Expert depositions

The expert has likely been deposed before—explore special considerations for expert depositions including how to set up
a Daubert motion, your trial cross-examination, or even increase your chances of settlement.

Identifying your deposition style
Playing to your own strengths will help you achieve your deposition objectives (and feel comfortable while doing so).
Identify your own deposition style by examining a showcase of various, successful models.

[Part IV: 1 Hour, 24 Minutes]

Deposition technology

The court reporter is an officer of the court. Your ethical interaction with the reporter as well as the proper use of technology,
including video, Realtime, and electronic exhibits increase your likelihood of a successful deposition.

Ethical pitfalls to avoid
When there is a transcript, there is room for error. This section reviews recent case law providing deposition guidance and
offers advice for avoiding ethical missteps.
 

[Adjourn]