Advanced Deposition Preparation: Witness Dynamics, Remote Depositions, Objections, Safeguards, Exhibits, and Use of Evidence (2025 Edition)

Michael J. Needleman
Randall Kanhke
Bryan Washburn
Michael J. Needleman | Reger Rizzo & Darnall LLP
Randall Kanhke | Faegre Drinker Biddle & Reath LLP
Bryan Washburn | Faegre Drinker Biddle & Reath LLP
On-Demand: January 27, 2025

3 hour CLE

This program is only available to All-Access Pass Members.
Subscribe to Miami-Dade Bar + myLawCLEs All-Access Pass...
Get this course, plus over 1,000+ live webinars.
Learn More

Program Summary

This comprehensive course is designed to help attorneys master the art of depositions, from strategic planning to effective witness preparation. The first session covers the critical aspects of depositions, including their strategic importance, the governing rules, and effective objection handling, offering valuable techniques for success. The second session explores the psychology of witness dynamics and provides actionable strategies for preparing witnesses to perform confidently under questioning. Together, these sessions equip attorneys with the skills needed to maximize the value of depositions, maintain control of the process, and enhance case outcomes.

Session I – Mastering Depositions: Strategic Approaches, Rules, and Techniques for Success – Michael Needleman

If you’re getting ready to take or defend your first deposition, or if you are about to take or defend only the latest deposition in a longer career, this course is for you. We will go over why a deposition is being taken; the rules governing depositions; what can and cannot be gotten away with; how to make and handle objections; and try to have a few laughs on the way.

Depositions are the cornerstone of any litigation, and getting a deposition right (or mostly right, anyway) can put your case (whether you are bringing the case or defending it) can save time and money and might even be useful at trial.

Key topics to be discussed:

  • Purpose and Strategic Importance of Depositions in Litigation
  • Rules and Boundaries in Deposition Practice
  • Objections: Making and Handling Them Like a Pro
  • Practical Techniques and Strategies for Successful Depositions

Session II – Mastering Witness Preparation: Psychology, Strategy, and Techniques for Effective Depositions – Randall Kahnke and Bryan Washburn

Depositions often pivot on how well witnesses perform under questioning. This session explores the psychology behind witness dynamics and provides actionable strategies for preparing witnesses to remain calm, clear, and confident during their depositions. Learn how to adapt your questioning witness-preparation techniques to different witness types, anticipate opposing counsel’s strategies, and maintain control of the deposition environment. This session is perfect for attorneys who want to sharpen their skills in witness preparation and maximize the value of every deposition.

Key topics to be discussed:

  • Identifying and Addressing Common Witness Pitfalls
  • Tailoring Preparation Strategies to Witness Personality Types
  • Anticipating Cross-Examination Techniques: Maintaining Poise Under Pressure
  • 3 Preparing Difficult Witnesses and Anticipating Hostile Opposition
  • Leveraging Creative Corporate-Representative Strategies

This course is co-sponsored with myLawCLE.

Closed-captioning available

Speakers

Michael J. Needleman | Reger Rizzo & Darnall LLP

Michael J. Needleman is a Partner in the Firm’s Philadelphia Office and member of the Litigation, Insurance, Employment Practices, Franchise & Distribution, and Corporate & Business Services Groups. He is a litigator in state and federal courts in Pennsylvania, New Jersey, and the District of Columbia. A former law clerk, he has been actively trying cases for more than a decade. He has extensive experience handling insurance defense, insurance coverage, employment litigation, and complex commercial litigation matters, including litigating franchise dispute matters.

Mr. Needleman has delivered lectures to the insurance industry on various topics and has taught several CLE classes on a variety of litigation-related subjects. He has also conducted training seminars for employers on maintaining harassment-free workplaces and minimizing claims.

 

Randall Kanhke | Faegre Drinker Biddle & Reath LLP

A Chambers-ranked attorney who is listed in Best Lawyers in America for bet-the-company litigation. He has been the lead trial attorney on cases from New York to California and touching three continents. Randy represents clients in complex commercial and intellectual property litigation, and he has served as group head of the firm’s business litigation practice.

Randy was recognized for his trial victories as a Minnesota Attorney of the Year. He is the co-editor, with the former deputy director general of the World Intellectual Property Organization, of the treatise, Trade Secrets (Law Journal Press), and the acclaimed book, The Secrets to Winning Trade Secret Cases (Thomson West). He was also a founding member of the Sedona Conference working group on trade secrets. Randy has served as the co-chair of the Magistrate Judge Merit Selection Panel for the United States District Court for the District of Minnesota. He has also served on the Federal Practice Committee of the United States District Court for the District of Minnesota and as president of the Minnesota Chapter of the Federal Bar Association. Randy is a former federal law clerk, a Fellow of the Litigation Counsel of America, and he has been recognized as a leading litigator in Chambers USA, Legal 500, Benchmark Litigation, Super Lawyers and Best Lawyers in America.

 

Bryan Washburn | Faegre Drinker Biddle & Reath LLP

Bryan Washburn litigates complex commercial disputes on behalf of businesses, with a focus on trade secret and noncompete litigation, as well as international arbitrations.

Bryan represents clients in trade-secret litigation and counsels clients in pre litigation matters. He has experience investigating alleged trade-secret theft in advance of litigation, initiating trade secret actions and defending against claims of trade secret misappropriation. Bryan also has experience advising clients on their trade-secret protection policies and procedures.

He represents employers in restrictive covenant disputes, including disputes over the enforceability and scope of non-compete and non-solicitation agreements. Bryan also has experience representing clients in pre-suit investigations, and making and responding to pre-suit demands.

Bryan represents clients in international arbitrations and advises clients on international arbitration strategy. Bryan has represented U.S. clients in foreign arbitration tribunals and international clients in domestic tribunals covering a range of contract and post-merger disputes.

With a particular emphasis on housing rights for tenants, Bryan maintains an active pro bono practice. He had an integral role on a team representing a tenants’ advocacy organization in a high-profile, 17-day trial against a major Minneapolis landlord, which resulted in a trial victory and a large sanctions award against the landlord.

Agenda

Session I – Mastering Depositions: Strategic Approaches, Rules, and Techniques for Success | 1:00pm – 3:10pm

  • Purpose and Strategic Importance of Depositions in Litigation
  • Rules and Boundaries in Deposition Practice

Break | 2:00pm – 2:10pm

  • Objections: Making and Handling Them Like a Pro
  • Practical Techniques and Strategies for Successful Depositions

Break | 3:10pm – 3:20pm

Session II – Mastering Witness Preparation: Psychology, Strategy, and Techniques for Effective Depositions | 3:20pm – 4:20pm

  • Identifying and Addressing Common Witness Pitfalls
  • Tailoring Preparation Strategies to Witness Personality Types
  • Anticipating Cross-Examination Techniques: Maintaining Poise Under Pressure
  • 3 Preparing Difficult Witnesses and Anticipating Hostile Opposition
  • Leveraging Creative Corporate-Representative Strategies
More CLE Webinars
Upcoming CLE Webinars
Dispositive Motions in Federal Court and Florida State Court
Dispositive Motions in Federal Court and Florida State Court Wed, March 19, 2025
On-Demand
Live Replay
Insurance and Bad Faith Litigation in Fire Loss Cases
Insurance and Bad Faith Litigation in Fire Loss Cases Thu, March 20, 2025
On-Demand
Live Replay
Divorce Law 101 (2025 Edition)
Divorce Law 101 (2025 Edition) Fri, March 21, 2025
Live Webcast
Gun Trust 101 (2025 Edition)
Gun Trust 101 (2025 Edition) Fri, March 21, 2025
On-Demand
Live Replay
Ethical Strategies with Law Firm Podcasts
Ethical Strategies with Law Firm Podcasts Mon, March 24, 2025
Live Webcast
AI-Generated Trade Secret Litigation
AI-Generated Trade Secret Litigation Wed, March 26, 2025
Live Webcast
1031 Exchanges 101 (2025 Edition)
1031 Exchanges 101 (2025 Edition) Thu, March 27, 2025
On-Demand
Live Replay
Drafting for Legal Professionals in Real Estate
Drafting for Legal Professionals in Real Estate Wed, April 2, 2025
Live Webcast