Everyone knows that something unexpected will crop up during a deposition – and you need to always be ready for what might come your way. Perhaps you're in the habit of anticipating what may come – however, this strategic instruction can give you the skills you need to turn the tables, so you're in the driver's seat. Although proper preparation before taking or defending a deposition is essential, you also need to be able to think on your feet and deliver the unexpected.

Enhance your decision-making skills during a deposition, master the essential planning stages and prepare for a smooth delivery on the day of the deposition itself. Order today to develop a flexible style that will help you handle any situation that comes your way.

1. Preparing for the Deposition
2. Preparing the Witness
3. Ethical Considerations
4. Taking the Deposition
5. Defending the Deposition
6. Looking Ahead – How to Use Deposition Testimony in the Case

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1. PREPARING FOR THE DEPOSITION
   9:00 - 10:00, Written by Robert F. Morris.
   Presented by Robert F. Morris in Allentown and Andrew D. Bigda in Scranton.
1. When to Take a Deposition, When to Pass
2. Common Mistakes to Avoid When Choosing Experts
3. Developing Your Discovery Strategy
4. Factor in the Financial Risks
5. What is the Purpose of the Deposition?
6. Knowing the Rules: FRCP and State
7. Deposition Notices and Priority
8. Past Interviews and Discovery Revisited
9. Preparing Exhibits
10. Preparing for Various Personalities: Deponents and Opposing Counsel
2. PREPARING THE WITNESS
   10:15 - 11:00, Written by Michael J. McDonald.
   Presented by Robert F. Morris in Allentown and Michael J. McDonald in Scranton.
1. Paint a Picture of Players, Setting and Recording Equipment
2. Discuss Clothing, Body Language, Pace, Tone and Voice
3. The Witness's Role: Do's and Don'ts
4. Update the Witness on all the Facts and Documents
5. What to Expect From Opposing Counsel
3. ETHICAL CONSIDERATIONS
   11:00 - 12:00, Written by Andrew D. Bigda.
   Presented by John P. Karoly III in Allentown and Andrew D. Bigda in Scranton.
1. Rules of Professional Conduct as They Relate to Depositions
2. Potential Conflicts of Interest
3. Attorney-Client Privilege and Work-Product Doctrine
4. TAKING THE DEPOSITION
   1:00 - 2:00, Written by Michael A. Genello.
   Presented by George E. Saba Jr. in Allentown and Michael A. Genello in Scranton.
1. Handling the Preliminaries
2. Setting the Tone
3. Choose Your Style: Conversation vs. Interrogation
4. What Questions to Ask? How to Phrase Them?
5. The Art of Listening
6. Creating Controversy to Show Deponent's Personality
7. Using Exhibits and the Witness File
8. Handling Objections
9. Special Considerations for Expert Witness
5. DEFENDING THE DEPOSITION
   2:15 - 3:15, Written by George E. Saba Jr.
   Presented by George E. Saba Jr. in Allentown and Michael A. Genello in Scranton.
1. Teach Your Witnesses to Listen to You Carefully
1. How to React to Attorney-Client Privilege Objections
2. How to React to Problematic Question Objections
3. What “I Need a Break” Really Means
2. Control With Articulation vs. the Boisterous Approach
3. Strategy, Tips and Techniques
6. LOOKING AHEAD – HOW TO USE DEPOSITION TESTIMONY IN THE CASE
   3:15 - 4:30, Written by John P. Karoly III.
   Presented by John P. Karoly III in Allentown and Michael J. McDonald in Scranton.
1. Ideas Spun From What You Learn at the Deposition
2. Post-Deposition File and/or Client Memoranda
3. How to Use Depositions Throughout Discovery
4. Revisiting Litigation Strategy
5. How to Use Depositions at Trial

JOHN P. KAROLY III is an attorney with Karoly Law Firm, LLC, where his areas of practice include criminal defense, personal injury, civil rights, white collar crime, corporate litigation, automobile accidents, medical malpractice, slip and fall, federal civil practice and construction law. He is admitted to practice in Pennsylvania and New Jersey, the U.S. District Court, Middle and Eastern Districts of Pennsylvania, and the U.S. Court of Appeals, 3rd Circuit. Mr. Karoly earned his B.A. degree from Rhodes College and his J.D. degree from Penn State - Dickinson School of Law. He is a member of the Lehigh County and American bar associations, the Pennsylvania Trial Lawyers Association and the Pennsylvania Association of Justice.

ROBERT F. MORRIS is a shareholder in the law firm of Morris and Clemm, P.C. His personal injury litigation practice includes medical malpractice, product liability and automobile accidents. He also handles complex commercial litigation and environmental litigation. Mr. Morris received his undergraduate degree from Yale University and his J.D. degree from Temple University School of Law. He is a Board Certified Civil Trial Advocate by the National Board of Legal Specialty Certification. Mr. Morris is a Fellow in the Litigation Counsel of America and a member of the Million Dollar Advocates Forum. A practicing civil trial lawyer since 1976, he was elected President of the Montgomery Bar Association in 2008 after having served as its Vice-President and Treasurer, and has chaired its Judiciary, Alternative Dispute Resolution, Insurance and Unauthorized Practice Committees. He is a member of the House of Delegates of the Pennsylvania Bar Association. Mr. Morris also has served as a hearing committee member for the Disciplinary Board of the Supreme Court of Pennsylvania. He was selected as a Pennsylvania Super Lawyer from 2008 through 2011.

GEORGE E. SABA JR. is a partner in the law firm of Swartz Campbell, LLC, in Allentown. He received his B.A. degree, magna cum laude, from Wilkes College and his J.D. degree from Delaware Law School. He is a past president of the Northeastern Pennsylvania Trial Lawyers Association and is an active member of several local, state and national bar and trial lawyer's organizations. Mr. Saba is board-certified in trial advocacy by the National Board of Trial Advocacy and has been certified as a Fellow by the Litigation Counsel of America. He is recognized as a Pennsylvania Super Lawyer by Philadelphia Magazine. Mr. Saba has published numerous articles on under/uninsured motorist law, bad faith and insurance coverage litigation. He has lectured in the past for several professional organizations including the Pennsylvania Bar Institute, Pennsylvania Trial Lawyers Association and National Business Institute.

ANDREW D. BIGDA is a partner in the law firm of Rosenn, Jenkins & Greenwald LLP, where he focuses his practice in criminal defense and personal injury litigation. Mr. Bigda was the assistant district attorney for Luzerne County from 1995-2000. He has tried more than 50 jury trials to verdict. Mr. Bigda was previously an adjunct faculty member at Luzerne County Community College. He earned his B.A. degree from St. Lawrence University and his J.D. degree from Catholic University of America. Mr. Bigda is a member of the Pennsylvania Bar Association, Wilkes-Barre Law and Library Association, Pennsylvania Association for Justice, American Association for Justice, Northeast Pennsylvania Trial Lawyers and the National Association of Criminal Defense Lawyers.

MICHAEL A. GENELLO is a partner in the law firm of Murphy, Piazza & Genello, P.C., where he focuses his practice in civil litigation, primarily on the defense side. He has lectured for the Lackawanna Bar and Pennsylvania Bar Association. Mr. Genello received his B.S. degree, magna cum laude, from the University of Scranton and his J.D. degree, summa cum laude, from Dickinson School of Law, where he was first in his graduating class. He is a member of the American, Pennsylvania, and Lackawanna bar associations, the Defense Research Institute, and the Pennsylvania Defense Institute.

MICHAEL J. McDONALD is a founding partner in the law firm of McDonald & MacGregor, LLC, where he practices in the areas of civil litigation and personal injury. He is certified as a civil trial advocate by the National Board of Trial Advocacy. Mr. McDonald has spoken for various professional groups on his areas of practice. He is past president of the Lackawanna County Bar Association and is a member of the Pennsylvania (member, Civil Rules Committee), the American and the Federal (past president, Middle District of Pennsylvania) bar associations, and the Middle District of Pennsylvania Lawyers Advisory Committee. Mr. McDonald also is the past president of the Northeastern Pennsylvania Trial Lawyers Association and is a member of the Pennsylvania Trial Lawyers Association, the American Association for Justice (member, Workplace Injury Litigation Group) and the American Board of Trial Advocates. He earned his B.A. degree from Villanova University and his J.D. degree from the Dickinson School of Law.

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