• 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

Freedland Harwin Valori & Gander

  • Partner at Freedland Harwin Valori & Gander
  • Board-Certified Civil Trial attorney with nearly 30 years of experi-ence in the legal profession
  • Focuses practice on catastrophic personal injury, wrongful death, medical negligence, and bad faith claims against insurance compa-nies
  • Undergraduate and law degrees from the University of Miami
  • Consistently obtained multimillion dollar verdicts and settlements for clients throughout her career.
  • Member of several boards and committees along with the highest rating in Martindale Hubbell
  • Has been repeatedly named one of the 10 Best Attorneys in Florida by the American Institute of Personal Injury Attorneys and received the Lifetime Achievement Award from America‚Äôs Top 100 Attorneys

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