Deposing Witnesses for Trial Advance Your Skills in Taking and Defending Depositions!
Why Attend?
Skillful questioning of a witness during a deposition can give you valuable information for trial. It also can assist you in evaluating the strengths and weaknesses of your witnesses and those of opposing counsel. Taught by experienced national trial skills instructors, this 3-hour program examines:
How to take and defend a deposition
How to use a deposition to your client’s advantage at trial
A must for both new and experienced attorneys, this practical program shows you how to depose a witness confidently, including how to begin the deposition, exhaust recollection, and handle exhibits, objections, and opposing counsel. You then learn useful strategies to protect your witness when defending a deposition. Finally, you are shown how to use depositions at trial, and remain ethical and professional throughout the deposition process.
A videotape of a mock deposition is interspersed throughout the program. The videotaped segments highlight the do’s and don’ts of deposing witnesses and serve as a springboard for more in-depth instruction. Time is reserved for questions and answers throughout the program.
Planning Chairs
David A. Sonenshein, I. Herman Stern Professor of Law at Temple University School of Law in Philadelphia, is an experienced teacher of deposition skills, evidence, and trial advocacy. Professor Sonenshein, the recipient of the prestigious 2001 Francis Rawle Award for his outstanding contributions to the field of post-admission legal education, is the creator and co-author of an innovative course in Evidence, entitled Trial Evidence — Making and Meeting Objections (National Institute for Trial Advocacy 1990, with Anthony J. Bocchino), as well as the co-author, also with Anthony J. Bocchino, of A Practical Guide to Federal Evidence: Objections, Responses, Rules and Practice Commentary (National Institute for Trial Advocacy 1996) and Federal Rules of Evidence with Objections (National Institute for Trial Advocacy 1995). He also co-authored the Evidence casebook entitled Principles of Evidence with Irving Younger and Michael Goldsmith (Anderson Publishing Company, 3rd Edition, 1997).
Howard Bruce Klein specializes in civil litigation, white collar criminal defense work, and qui tam litigation in his own law firm in Philadelphia. He also is the Director of ALI-ABA In-House, teaching deposition skills, evidence, and trial advocacy to law firms and government agencies nationwide. He is a highly regarded trial lawyer and teacher, formerly a partner and Chairman of the Litigation Department at the firm of Blank Rome, LLP, in Philadelphia. He also is a former federal prosecutor, having served as Chief of the Criminal Division of the U.S. Attorney’s Office for the Eastern District of Pennsylvania. A graduate of Georgetown University Law Center, Mr. Klein is a teacher of Trial Advocacy and Evidence as an Adjunct Professor of Law at Temple University School of Law, and has taught for the National Institute for Trial Advocacy and for the Attorney General’s Advocacy Institute. He is the author of a new casefile, Fogarty & James v. Portex Communications, Inc., used in deposition and trial advocacy programs, and has written and lectured extensively on the topics of trial advocacy, deposition training, and the criminal justice system.
Program Schedule
- Taking the Deposition
- Starting the deposition
- Background of the witness
- The witness’s business
- Exhausting recollection
- Handling conversations
- Handling exhibits
- Handling objections
- Handling opposing counsel
- Discovery vs. admissions
- Lock-in of the witness
- The Use of Depositions at Trial
- Impeachment
- Admissions
- In lieu of absent witness (former testimony)
- Refreshing recollection
- Offer of proof
- Defending the Deposition
- Objections
- Attorney-client privilege
- Work product immunity
- Instructions not to answer
- Protecting the witness
Total 60-minute hours of instruction: 3.0 (50-minute hours: 3.6)


