There is an art and a science to taking a deposition and knowing which questions to ask is a key element to taking a great one.

This CLE course will present the most sophisticated techniques to drafting questions that will take your deposition from good to great. The course will explain the documents that are essential to crafting questions and how to formulate those questions to achieve your goals. Wording, pleadings, discovery responses, the use of exhibits, audio and video materials and other documents will be presented.

The course will address how to anticipate and overcome objections and other key techniques such as the strategic use of open-ended and closed-ended questions, exhaustion, warm and cold questions, conversational and other style forms of questioning. Fact v. expert witness depositions and the strategies to apply for each as well as how to prepare witnesses will be presented.

The course will conclude with tips to avoid common errors and surefire approaches to ensure success.