Essentials of Depositions Seminar Materials

Publication Date: February 2018
Available Formats: Searchable PDF via immediate download
Pages: 40


This comprehensive, stand-alone publication is direct from a February 2018 seminar.

Depositions have become a “standard” part of most cases, sometimes without much thought given to how they will advance the cause at trial. They are expensive and time consuming. Opposing counsel can make the experience frustrating at best. Utilizing the results of the deposition at trial can be difficult, yet if done right, they can be an incredibly useful tool. If you don’t have a seasoned partner sitting second-chair, how do you know whether you are doing it right?

Topics covered in this seminar include:

  • When is a deposition appropriate?
  • The mechanics of a deposition in Virginia
  • Should the deposition be video-recorded?
  • Choosing “virtual” depositions—video and phone depositions
  • The use of documents at deposition
  • Objections at deposition
  • Identifying deposition objectives and varying techniques depending on those objectives
  • How to get what you need from the reluctant witness
  • How to deal with difficult opposing counsel and when to call the judge
  • Deposition-related motions
  • Special situations (4:5(b)(6) depositions; foreign depositions)
  • The use of deposition transcripts at trial
  • Impeachment with a deposition at trial
  • The use (and abuse) of errata sheets

Copyright © 2018 Virginia Law Foundation. All rights reserved.

Table of Contents

I. The Rules

II. The Basics

III. Practice Pointers

IV. Witness Preparation

V. Depositions of Experts

VI. 30(b)(6)/4:5(b)(6) Depositions

Appendix A. Notice to Take Deposition

Appendix B. Notice to Take Video Deposition

Appendix C. Notice of Video Deposition with Exhibit

Appendix D. Rule 30(b)(6) Notice

Appendix E. Rule 4:5(b)(6) Notice


James F. Neale

M. Bryan Slaughter


Essentials of Depositions

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