Advanced Depositions College

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Advanced Depositions College 

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January 17, 2014 - January 20, 2014
Westin Canal Place
New Orleans, LA

Strengthen your deposition skills with top-notch AAJ faculty in New Orleans at AAJ's Advanced Depositions College.  This program provides the strategies and techniques to enhance the performance of even the most experienced plaintiff trial lawyer at the deposition table.

Built on the fundamentals of AAJ’s Depositions College, the Advanced Depositions College provides an in-depth, cutting-edge approach to perfecting depositions and witness preparation skills. This program features a low student-to-faculty ratio, comprehensive lectures, useful demonstrations, and five workshops—which will be recorded for you to take home—to prepare you for success in depositions and in the courtroom. During the workshops, you will practice your new skills and receive critical feedback from the experienced faculty.

Learn and practice advanced techniques in recorded workshops:

  • Discovery plans and witness goals
  • Lay witnesses: Exhaustion, boxing-in, restating and summarizing, nonverbals, mirroring
  • Document discovery/"Death star" depositions
  • Establishing standards of care and conducts
  • Deposing experts

"The workshops were the best. I liked how techniques taught in the workshops were immediately applicable."
--John P. Neblett, Camp Hill, PA, 15 years in practice

"It was terrific to get instruction from the impressive attorney panel that taught this course!"
--Colonel Peter R. Masciola, Washington, DC, 29 years in practice

New Publication!  Advanced Depositions Strategy and Practice from Phillip Miller and Paul J. Scoptur

Authors Phillip Miller and Paul Scoptur, faculty and course advisors for AAJ Education’s Advanced Depositions College, bring you comprehensive training on depositions in their new release, Advanced Depositions Strategy and Practice.  This publication, brought to you by AAJ and Trial Guides, includes Miller and Scoptur’s proven tactics for how to elicit the information you need to support your case theory and craft a cohesive, convincing trial theme.  Learn how to nail down case-critical facts, decide on questioning approaches, use juror attitudes and beliefs to your advantage, maintain control of witness’ testimony, and handle evasive, hostile, uncooperative, opposing, and expert witnesses. AAJ will be providing a complimentary copy of the book to each attendee.

Take your study further with Miller and Scoptur’s new Advanced Deposition Strategy and Practice DVD and CD set, including case strategy and planning for depositions, establishing standards and rules, dealing with difficult witnesses, and deposing the defense medical examiner. Benefit from the authors’ thirty-plus years of experience and learn how to apply their strategies and techniques to improve your deposition skills.  For more information on the materials available, please click here.

Friday, January 17


Welcome and Introductions

Developing a Discovery Plan
• How juror attitudes affect your deposition strategy
• Making these attitudes work for you in depositions
• Linking premises to conclusions
• The role of logic in developing your plan
Sach D. Oliver, AR

The 30(b)(6) notice: Strategy and Practice
• Goals
• What are the case central issues to explore?
• Crafting the notice of deposition
Mark R. Kosieradzki, MN

Workshop: Discovery Plan and Witness Goals
• What attitudes apply
• Goals for each lay witness—three take-aways
• What are the landmines for each case?
• How do we make the defenses irrelevant, incorrect or immaterial

“Death Star” Depositions: Combining the 30(b)(2), 30(b)(6) and 34 Deposition into the Death Star
• Finding all the documents
• Using a 30(b)(2) deposition to discover case dispositive information
• Altered records: Lock the defendant in, then impeach with the originals
• Using the “smoking gun” document
Mark R. Kosieradzki, MN

Deposing the Difficult/Evasive Witness
• One fact, one question
• Using exhibits for control
• Establishing deposition protocol/rules
Michael D. Doyle, TX

Deposition Techniques
• Exhaustion
• Boxing-in
• Restating and summarizing
• Nonverbals, mirroring 
Thomas S. McGrath, AL

Workshop on Lay Witnesses: Exhaustion, Boxing-in, Restating and Summarizing, Nonverbals, Mirroring

Saturday, January 18


Establishing Standards of Care and Conduct with Defense Witnesses
Render C. Freeman, GA

Using Neuroscience, Decision Making and Storytelling in Deposition
• Shared common experience
• Social pigeons
• Using rhetorical questions in depositions
Robyn L. Wishart, BC

Workshop: Document Discovery/“Death Star” Depositions


Critical Thinking: Anticipating the Defenses
• Finding Landmines and rebuttals
• Finding the facts that make the landmines irrelevant, immaterial or incorrect
Phillip H. Miller, TN

Workshop: Establishing Standards of Care and Conduct

Sunday, January 19


Dealing with the Rambo Litigator (ethics)
• Use of ethics rules
• Use of deposition protocol
Redwood v. Dobson
Richard D. Hailey, IN

Witness Preparation
• The dos and don’ts
• Unpacking the witness & setting the tone
• Practice Q & A: Diagnosing witness strengths and weaknesses
• Delivering quality feedback
• Checking in with your witness to assess the prep
Robyn L. Wishart, BC

Special Considerations for Deposing Experts
• Establishing facts and theories favorable to your case
• Silver bullets
Elise R. Sanguinetti, CA


Deposing the DME
• Establishing bias
• Polarizing your case
• Hitchhiking
Paul J. Scoptur, WI

How NOT to depose the DME
• What words not to use
• Video examples of what not to do
Phillip H. Miller, TN

Workshop: Deposing Experts and Storytelling in Depositions

Monday, January 20


How to Effectively Record Your Depositions
• How to do your own video
• Software, hardware
• Use at trial
Thomas S. McGrath, AL

Considerations when Deposing Specific Witnesses
• Eyewitness
Elise R. Sanguinetti, CA
• Treating physician
Richard D. Hailey, IN
• Economist
Sach D. Oliver, AR
• Vocational/life care planner
Michael P. Doyle, TX
• Trucking expert
Render C. Freeman, GA

Bringing It All Together
• Summarization of key points from each lecture
• Vignettes for key points
Moderator: Paul J. Scoptur, WI
All faculty

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