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

1. PREPARING FOR THE DEPOSITION
   9:00 - 10:00, John A. Snow
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
   10:00 - 10:45, John A. Snow
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, John A. Snow
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, Michael P. Petrogeorge
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
   2:00 - 3:15, Roger Griffin
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
   3:30 - 4:30, Ron Kramer
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

ROGER GRIFFIN is a senior litigation attorney with Craig Swapp & Associates where his practice focuses on litigating, mediating, and arbitrating cases involving car accidents, truck accidents, negligence injury, wrongful death, and complex business disputes. Mr. Griffin practices in Utah and Idaho. He also heads up the firm's criminal law section. He graduated cum laude from Utah State University with his Bachelor of Arts degree in Political Science and he earned his Juris Doctor degree from Brigham Young University's J. Reuben Clark Law School, where he served as vice president of the Student Bar Association and was a recipient of the Faculty Award. Since 2007, he has been named one of the "Utah Legal Elite" by the Utah Business Magazine. Professionally, Mr. Griffin also has expertise in family law and appellate work. He is a member of the Utah Association for Justice and the Utah Association of Criminal Defense Lawyers.

RON KRAMER is a partner in the Kramer Law Group in Salt Lake City. His personal injury practice is focused on representing those injured by the negligence of others. Mr. Kramer is a graduate of Brigham Young University and the University of the Pacific, McGeorge School of Law. He is currently a governing board member of the Utah Association of Justice (UAJ), where he currently serves as chairperson of the Education Committee and is involved in planning continuing legal education seminars that the UAJ sponsors. Mr. Kramer further serves as one of the Utah delegates to the American Association of Justice (formerly ATLA, the Association of Trial Lawyers of America).

MICHAEL P. PETROGEORGE is a shareholder in the firm of Parsons, Behle & Latimer, P.C., where he concentrates his practice in real estate and complex commercial litigation. He heads the Real Estate Litigation Practice group for the firm. Mr. Petrogeorge received his B.A. degree in political science and criminal justice from Gonzaga University. He received his J.D. degree from the University of Utah College of Law and is a member of the Order of the Coif. During law school, Mr. Petrogeorge was a William H. Leary Scholar and, upon graduation, received the West Group Outstanding Scholastic Achievement Award for best overall scholastic performance. He served as a law clerk for the Honorable Stephen H. Anderson on the United States Tenth Circuit Court of Appeals. Mr. Petrogeorge previously served on the Executive Committee of the Litigation Section of the Utah State Bar, serving as its chair in 2007-2008. He was named as a member of the Utah Legal Elite, Utah Business Magazine, 2006 and 2007 and a Rising Star, Mountain States Super Lawyers Magazine, 2008. Mr. Petrogeorge is a member of the Washington State Bar and the American Bar Association. He serves as an adjunct professor at the University of Utah, S.J. Quinney College of Law.

JOHN A. SNOW is a shareholder at Van Cott, Bagley, Cornwall & McCarthy, with offices in Utah and Nevada. His practice consists of general civil litigation, including general commercial and business litigation, construction, insurance, professional malpractice and personal injury. Mr. Snow was named in The Best Lawyers in America in the areas of legal malpractice, construction and commercial litigation. He also is designated in Utah Business Magazine's Utah Legal Elite in the specialty of civil litigation and as Super Lawyer in the Mountain States Super Lawyers Magazine. Mr. Snow speaks extensively in Utah and Nevada for various business and professional groups on his areas of practice. He is a member of the Utah State Bar, the State Bar of Nevada and the American Bar Association. Mr. Snow earned his B.A. degree from Brigham Young University and his J.D. degree, cum laude, from Arizona State University.

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