• 8 minutes

Cutting the Deposition for Trial


Have your cross-examination ready to go.

If you present testimony by deposition on direct, you need to provide opposing counsel with page/line designations well in advance of trial. Opposing counsel then gets the opportunity to object to your designations and offer their counter-designations. You then get to object to the counter-designations. Then, the attorneys need to confer to see what they can work out. Anything that cannot be worked out requires a judicial ruling, preferably well in advance of trial so the depositions can be cut for straight-play if they are videotaped and you do not waste the court’s or the jury’s time in the middle of trial to get the rulings. This video reviews page/line designations for direct and cross-examination and discusses whether or not to use the transcript or video during cross-examination.
Runtime: 8 minutes



Deborah J. Gander

Deborah J. Gander

Colson Hicks Eidson

  • Partner at Colson Hicks Eidson since 2002
  • Has dedicated her career to helping victims receive justice
  • Board certified civil trial lawyer with more than $100 million in verdicts and settlements for her clients
  • Represents clients who have suffered catastrophic injuries or who have lost family members; also represents clients who face financial ruin because of insurance company bad faith
  • Has 20 verdicts exceeding $1 million
  • Includes an award that was the largest ever in a Federal Tort Claims Act Case: $61 million for medical negligence at a Naval hospital, and was the first time in history the U.S. government was held liable for the acts of a doctor it alleged was an independent contractor
  • Achieved the highest rating in the Martindale-Hubbell Law Directory, and includes her in the Martindale-Hubbell Bar Register of Preeminent Women Lawyers
  • Received the “Most Effective Lawyer” award for civil litigation in 2006 from the Daily Business Review
  • Has had two of her verdicts receive the Daily Business Review’s “Verdicts Hall of Fame Award”
  • Has been repeatedly named one of the “10 Best Attorneys in Florida” by the American Institute of Personal Injury Attorneys
  • Is an elected member, executive board member, and President of the Miami-Dade chapter of American Board of Trial Advocates
  • Co-chaired the Civil Litigation Committee of the Dade County Bar Association
  • Continues to lecture for organizations including the American Bar Association and American Association for Justice
  • Was a law clerk to the Honorable Peter T. Fay, Eleventh Circuit Court of Appeals
  • Graduate, magna cum laude, University of Miami School of Law; served as an adjunct professor there for several years
  • Can be contacted at 305-476-7400 or [email protected]

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