Effective Deposition Techniques: Controlling Conversations and Difficult Witnesses

James M. Susag
James M. Susag | Larkin Hoffman Daly & Lindgren Ltd

James M. Susag is a seasoned trial attorney with a focus on franchise and dealer disputes, real estate, and complex commercial matters. Jim has the unique perspective of a trial lawyer who has also managed complex litigation and developed strategic legal plans as in-house counsel

On-Demand: April 16, 2025

2 hour CLE

Tuition: $195.00
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Program Summary

In Effective Deposition Techniques: Controlling Conversations and Difficult Witnesses, we will cover strategies for handling various types of challenging witnesses. We will discuss techniques for dealing with forgetful, confused, or evasive witnesses by turning their lack of recollection into a credibility issue and using their evasiveness to the attorney’s advantage. For witnesses who provide vague answers, we will suggest establishing the attorney as a credible source of information and using documents to counter vague responses. We will also address handling lying witnesses by using the looping technique to reinforce their statements and impeach them with prior inconsistent statements.

Additionally, we will cover tactics for dealing with witnesses who talk too much, such as interrupting them to maintain control and using body language to stop them. Finally, we will provide strategies for managing uncooperative witnesses, including making them feel comfortable and using strategic sympathy to handle emotional responses. By the end of this presentation, you will have several new tools to employ to effectively handle difficult witnesses.

Key topics to be discussed:

  • Forgetful, Confused, Evasive Witnesses and Deponents who Respond with Vague Answers
  • The Liar and Tactical Approaches to Inconsistent Statements
  • Uncooperative, Hostile and Arguing Witnesses
  • Deponents with Mental Health Conditions or Diminished Capacity and Child Witnesses

Closed-captioning available

Speakers

James M. Susag_Larkin Hoffman_myLawCLEJames M. Susag | Larkin Hoffman Daly & Lindgren Ltd

James M. 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. Jim 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.

Agenda

I. Forgetful, Confused, Evasive Witnesses and Deponents who Respond with Vague Answers | 1:00pm – 1:30pm

II. The Liar and Tactical Approaches to Inconsistent Statements | 1:30pm – 2:00pm

Break | 2:00pm – 2:10pm

III. Uncooperative, Hostile and Arguing Witnesses | 2:10pm – 2:40pm

IV. Deponents with Mental Health Conditions or Diminished Capacity and Child Witnesses | 2:40pm – 3:10pm

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for Self-Study Credits
2 General

Arkansas

Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hour(s)

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2.5 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Pending CLE Approval
2 General

Hawaii

Approved for CLE Credits
2.4 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Approved for Self-Study Credits
2 General

Indiana

Pending CLE Approval
2 General

Kansas

Pending CLE Approval
2 Substantive

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hour(s)

Maryland

No MCLE Required
2 CLE Hour(s)

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hour(s)

Minnesota

Approved for Self-Study Credits
2 General

Missouri

Approved for Self-Study Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Approved for Self-Study Credits
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
2 General

Nevada

Pending CLE Approval
2 General

New York

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Pending CLE Approval
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for Self-Study Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hour(s)

Tennessee

Approved for Self-Study Credits
2 General

Texas

Approved for CLE Credits
2 General

Utah

Approved for Self-Study Credits
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved for Self-Study Credits
2 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Approved for Self-Study Credits
2 General

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Pending CLE Approval
2 General

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