• 25 minutes

Taking a Deposition to Preserve Testimony


Do not ask more than you need.

When planning the deposition it’s important to think of it as if It were a live trial testimony. You start with an introduction of the witness then cover factual information and case themes. Use legal terminology that meets your evidentiary standards and burden of proof. Re-ask if you do not get the required response initially. Make sure you ask questions that conform to the Rules of Evidence so you do not risk having them stricken later at trial. This video reviews these tips and also discusses witness attire and potential props.

Runtime: 25 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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