Crushing Experts: Depo Prep

Hour 1: Depo Prep

We will discuss how and what is needed to properly prepare to take the deposition/cross examination of defense paid witnesses. During this first hour, we will discuss how we research defense paid witnesses and how to organize this information for use in your deposition/cross examination. You will learn that the amount of time preparing for a successful deposition/cross examination takes way longer than the actual execution of the examination.

Hours 2 & 3: Mastering The Medicine

We will take a deep dive into the medicine. Dorothy and Sean will debunk the long-held belief of many plaintiff lawyers that lawyers should not challenge the defense paid witness on the medicine. Rather plaintiff lawyers have an obligation to their clients to learn the medicine and then directly challenge the defense paid witness on the medicine. Showing the jury that the defense paid witness is lying about the medicine not only cements the validity of your client’s injuries, but it also drives the verdicts and often leads to larger verdicts because juries hate when doctors lie about the medicine.

Hour 4: Negative Space

Bruce Schechter is a master of “Negative Space” cross examination. Dorothy and Sean will demonstrate how the use of negative space is used in the examination of defense paid medical witnesses. We will use actual clips from trials and depositions. You will leave this hour knowing what “Negative Space” is and how you can implement it in your next examination.

Hour 5: To Depose Or Not To Depose

We will discuss the strategy in determining whether to depose a defense paid witness or to wait until trial to cross examine them. If the decision is made to depose a defense paid witness, we will explain how we use the transcript to draft motions to strike or limit the expert in their testimony at trial. The biggest fear of any paid witness is having orders striking or limiting their testimony, as this information will be used in future cases against them.

Hour 6: Q&A

This final hour will be used as a question & answer session. We will open the floor up for all attendees to ask the questions they are facing in the pending cases and we will help you figure out ways to overcome the obstacles you are facing in your cases.

TLU Live HB Agenda