Agenda / Content Covered

1:00 pm to 4:15 pm Eastern Standard Time

1:00 - 2:30, Kristina Ducos

1. Planning, Preparation and Purpose: Creative Pointers
   1. Where Most Depositions go Wrong
   2. Developing a Strong Theme and Staging the Deposition
   3. Thoroughly Investigating the Deponent
   4. Deposition Outline Pointers
   5. Controlling the Environment
2. Questioning Techniques of Seasoned Litigators
   1. Objectives and Style of Questioning
   2. Form of Questions and Answer
   3. Order
   4. Fertile Ground for Useful Admissions
   5. Preserving Your Strongest Questions
   6. Questioning Strategies for Different Personality Dynamics
   7. Successfully Handling Objections
   8. Top Questioning Mistakes Attorneys Make

2:45 - 4:15, David J. Horr

3. Masterfully Handling Difficult Deponents and Attorneys
   1. Forgetful, Confused or Evasive Witnesses
   2. Uncooperative Witnesses
   3. Hostile Witnesses
   4. Dealing with Rambo Tactics (Defending vs. Examining Attorney)
4. Leveraging Objections and Other Tactics for Defending Depositions
   1. Examining Attorney Tricks/Traps and Strategies to Evade Them
   2. Preparing Deponents for Experienced Opposing Counsel
   3. Leveraging Privileges and Deposition Objections
   4. Intervention: Opportunities, Timing and Pointers

Accreditation Details:

KRISTINA DUCOS is a lead attorney with Monge & Associates, P.C. Ms. Ducos focuses on complex personal injury litigation, including negligent security, dog bite liability, wrongful death, and catastrophic injury cases. Ms. Ducos received her B.S. degree from the University of North Carolina at Charlotte and earned her J.D. degree from Atlanta’s John Marshall Law School. While at John Marshall Law School, she graduated from the Criminal Justice Honors Program and was also a recipient of the Equal Justice of America Scholarship Award which promotes pro bono legal work for the community at large. Ms. Ducos began with Monge & Associates, P.C., in 2016 and has quickly become one of the highest rated attorneys at the firm for customer satisfaction. She is also the youngest attorney in the firm’s history to be promoted into a lead attorney position due to her excellent case results. In 2018, she was named as one of the Top 40 Under 40 Personal Injury Attorneys for the state of Georgia by the American Association of Trial Lawyers.

DAVID J. HORR is a partner in the Miami law firm of Horr, Novak & Skipp, P.A. His experience focuses on admiralty and maritime law, personal injury defense (crew and passenger claims), and marine insurance, as well as products liability and general casualty defense. Mr. Horr tries cases regularly throughout Florida. He has been a frequent speaker on topics relating to his areas of practice. Mr. Horr earned his B.A. degree from the University of Notre Dame and his J.D. degree from the University of Miami. He is a member of the American Bar Association (member, Litigation, Torts and Insurance Practice sections), American Board of Trial Advocates, The Florida Bar (Admiralty Law Committee), the Maritime Law Association of the United States, the Southeastern Admiralty Law Institute, the Defense Research Institute, and the Florida Defense Lawyers Association.