Strategies in Taking and Defending Depositions (2025 Edition)

Gerald A. Connor
Gerald A. Connor
Margolis Edelstein

Gerald A. 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.

Dennis Wilenchik
Dennis Wilenchik
Wilenchik & Bartness P.C.

Dennis Wilenchik is a nationally certified civil trial advocate with over 46 years of experience as a civil and white-collar criminal trial attorney.

Live Video-Broadcast: January 27, 2025
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3 hour CLE
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Program Summary

Session I - Effective Deposition Management: Rules, Roles, and Best Practices – Gerald A. Connor

This session will address approaches to narrowing or broadening the scope of depositions and examine various types, including those aimed at gathering discovery or establishing pivotal points through cross-examination. The session will also provide practical insights on handling depositions of corporate representatives, fact witnesses, and non-party witnesses. Additionally, they will cover essential procedures, permissible and impermissible objections, and strategies for preserving the record when issues arise during depositions.

Key topics to be discussed:

  • Limiting Depositions
  • Understanding the Nature of Depositions
  • Utilizing Videotaped Depositions Effectively
  • Conducting Depositions of Fact Witnesses
  • Best Practices for Depositions of Corporate Representatives
  • Navigating Depositions of Non-Party Witnesses
  • Permissible and Impermissible Objections During Depositions
  • Reviewing and Correcting Deposition Transcripts with Witnesses

Session II – Techniques and Strategies for Taking Depositions – Dennis Wilenchik

This session provides an in-depth exploration of the rules, strategies, and techniques essential for mastering depositions. Topics include the applicable rules of civil and criminal procedure, types of depositions, and preparation tactics for both taking and defending depositions. Attendees will learn how to formulate effective questions, handle problem witnesses, and navigate the unique challenges of remote depositions. Special focus will be given to expert witness depositions, ethics in witness preparation, and strategies for uncovering inconsistencies. Practical tips for controlling the narrative, using exhibits, and managing opposing counsel tactics will ensure participants leave equipped for success in any deposition setting.

Key topics to be discussed:

  • Applicable Rules of Civil Procedure
  • Types of Depositions
  • Preparing to Take the Deposition
  • Preparing Your Witness
  • The Expert Witness Depositions
  • Techniques for Taking Depositions

Date / Time: January 27, 2025

  • 1:00 pm – 4:20 pm Eastern
  • 12:00 pm – 3:20 pm Central
  • 11:00 am – 2:20 pm Mountain
  • 10:00 am – 1:20 pm Pacific

Closed-captioning available

Speakers

Gerald-A.-Connor_Margolis-Edelstein_myLawCLEGerald A. Connor | Margolis Edelstein

Gerald A. 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, insurance coverage and First Party 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 and is a frequent lecturer at both the State and National level.

 

Dennis-I.-Wilenchik_Wilenchik-&-Bartness,-P.C._myLawCLEDennis Wilenchik | Wilenchik & Bartness P.C.

Dennis Wilenchik is a nationally certified civil trial advocate with over 46 years of experience as a civil and white-collar criminal trial attorney. Renowned for his expertise, he has tried hundreds of cases to jury verdicts and handled numerous high-profile cases, earning multimillion-dollar verdicts and national recognition. He has served as a legal thought leader, author, and speaker at various prestigious legal seminars.

A former Chairman of the Arizona Bar Association’s Trial Practice Section, Mr. Wilenchik has held numerous leadership roles, including Co-Chair of the ABA Trial Practice Committee’s Sound Advice program and General Counsel for the Arizona Republican Party. His professional accolades include selection as a Super Lawyer in Business Litigation, Distinguished Lawyer of America, and repeated recognition as “Best Trial Lawyer in the Valley” by Arizona Foothills Magazine.

Mr. Wilenchik has represented a wide array of clients, including prominent political figures, major corporations, and state agencies. He has also contributed significantly to Arizona’s legal landscape, serving as a Judge Pro Tem, committee member for federal judicial appointments, and board member for various state and legal organizations.

Mr. Wilenchik graduated from South Texas College of Law and resides in Paradise Valley, Arizona, and continues to actively practice law while mentoring the next generation of attorneys at his firm, Wilenchik & Bartness, P.C.

Agenda

Session I – Effective Deposition Management: Rules, Roles, and Best Practices | 1:00pm – 3:10pm

  • Limiting Depositions
  • Understanding the Nature of Depositions
  • Utilizing Videotaped Depositions Effectively
  • Conducting Depositions of Fact Witnesses

Break | 2:00pm – 2:10pm

  • Best Practices for Depositions of Corporate Representatives
  • Navigating Depositions of Non-Party Witnesses
  • Permissible and Impermissible Objections During Depositions
  • Reviewing and Correcting Deposition Transcripts with Witnesses

Break | 3:10pm – 3:20pm

Session II – Techniques and Strategies for Taking Depositions | 3:20pm – 4:20pm

  • Applicable Rules of Civil Procedure
    • Notice
    • Limitations
    • Protective orders
    • Overview of Rules 27, 30, 31, FRCP, and Rule 15, FRCrimP
    • Sanctions for deposition misconduct
  • Types of Depositions
    • Fact witnesses
    • Corporate representatives
    • Expert witnesses
  • Preparing to Take the Deposition
    • Types of outlines and objectives
    • Using the correct question structure and formulating effective questions
    • Preparation for unexpected, evasive, and incomplete answers

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