• 16 minutes

Taking a Deposition to Set Up Cross-Examination at Trial


Gain insight into deposing the opposing party's main witness.

When it comes to deciding which witness(es) to depose, always depose the opposing party’s main witness(es), be they fact or expert witnesses. Unless, of course, your trial order requires extremely detailed expert reports that the deponent is bound by, and you have bias and credibility depositions or testimony from outside sources. It's important that you lock in the factual information and agreements so you cannot be surprised at trial. This video reviews ways to get the deponent to agree to obvious concessions and discusses why you should videotape some depositions but never others.

Runtime: 15 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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