COMBATING OBSTRUCTIONISM AT DEPOSITION
(presentations of 2.5 to 4 hours of teaching time)
8:30 - 10:00 a.m. (the 4 hour agenda)
- A "great" adverse deposition defined
- Cross-examiner's 2 lines of appeal to opposing attorney
- Combating obstructionism prior to the deposition day
- Admonitions in 4 cases (3 famous, 1 not so much)
- The very best set of admonitions
10:00 - 10:10 a.m. Break
10:10 - 11:20 a.m.
- A brilliant (or crazy) corollary to the "cooperation" admonition
- Obstructionism re the deposition breaks
- Obstructionism re the production of documents at deposition
- The three legitimate grounds re an instruction not to answer
- Cross-examiner's 4 failures re opposing attorney's objections
- Analysis of the universe of objections
11:20 - 11:30 a.m. Break
11:30 - 12:50 a.m.
- Analysis of the universe of objections (continued)
- A brilliant (or second crazy) idea re dealing with the persistently non-responsive witness
- Recording the deposition: the up-sides and the down-sides
- Obstructionism by the adverse expert