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Deposition Control

Becoming the Authority and Controlling the Conversation
Sybil Dunlop

Whether you are seeking information, an admission, or defending your client, your control of a deposition is critical to case success. Sybil Dunlop summons her varied experiences as a
successful trial lawyer and marries them with her remarkable teaching talent and excitement
for the practice of law to deliver a unique experience.


Both the novice and experienced will benefit from Sybil’s perspective on the art and
science of depositions. She will not present dictates, but will illuminate tactics and styles, to
help you fashion or improve your own approach. She will work with you to develop a
deposition persona that is uniquely personal and unquestionably successful!

  • Preparing your witness to succeed;

  • Drafting and using outlines;

  • Taking and defending depositions;

  • Effective objections;

  • Expert depositions;

  • Identifying your deposition style;

  • Deposition technology; and

  • Ethical pitfalls to avoid.


Program Agenda & Detail

6 Hours Including 1 Ethics


[Part I: 90 Minutes]


Preparing your witness to succeed

“Best practices” for preparing your witness include the use of documents during
preparation and the latest research to help your witness feel comfortable and perform at
his or her best.

Drafting and using outlines
While you never want to be tied to your outline, advance preparation allows you the
flexibility to move beyond the outline in a deposition. We’ll review several outline templates
to identify the styles that will work best in different circumstances.


15 Minute Break

[Part II: 90 Minutes]


Taking and defending depositions

Whether conducting a discovery deposition, a trial deposition, a hybrid or defending your
own witness, the fundamentals are crucial. Beyond those basics, though, Sybil provides
tips and tricks to elevate your performance.

Effective objections
When defending a deposition, the objection is your primary tool. This section covers
everything—from teaching your witness about depositions to effectively using them to
preserve your record.


[Part III: 90 Minutes]


Expert depositions

The expert has likely been deposed before—explore special considerations for expert
depositions including how to set up a Daubert motion, your trial cross-examination, or even
increase your chances of settlement.

Identifying your deposition style
Playing to your own strengths will help you achieve your deposition objectives (and feel
comfortable while doing so). Identify your own deposition style by examining a showcase
of various, successful models.


15 Minute Break

[Part IV: 90 Minutes]


Deposition technology

The court reporter is an officer of the court. Your ethical interaction with the reporter as well
as the proper use of technology, including video, Realtime, and electronic exhibits
increase your likelihood of a successful deposition.

Ethical pitfalls to avoid
When there is a transcript, there is room for error. This section reviews recent case law
providing deposition guidance and offers advice for avoiding ethical missteps.




Unconditional Guarantee
If you are not convinced that your understanding of the course topic has
improved after completion of any P.E.G.® seminar, we will refund your course tuition.



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