Advanced Deposition Techniques: Leveraging Exhaustion, Boxing-In, and Summarization Approaches With Adverse Witnesses

Recording of a 90-minute CLE webinar with Q&A

Conducted on Tuesday, March 14, 2017

Recorded event now available

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Program Materials

This CLE webinar will provide litigators with advanced techniques for conducting top-notch depositions in commercial litigation. The panel will discuss specific strategies for getting the most out of depositions, including exhaustion, boxing-in and summarization techniques for ordinary, hostile or evasive witnesses.


Depositions are an essential tools that commercial litigators use for many reasons. Among other things, depositions allow commercial litigators to gather the information they need to prove their client’s case, to disprove or undercut their adversary’s positions, to learn more about the underlying facts of the case, or to tee up a settlement or dispositive motion.

Depositions are often a key element both for pre-trial resolutions or for success at trial. The value of deposition testimony depends very much on the attorney’s approach. In that regard, commercial litigators must hone their skills with practiced techniques to elicit testimony and evidence critical to a favorable disposition of the case for their clients. Counsel must be particularly proficient in the techniques of exhaustion, boxing-in and summarizing.

If implemented correctly, these techniques will give the commercial litigator the best shot at gathering vital information from even the most difficult or evasive deposition witnesses. Conducting depositions using these best practices can also provide information needed to impeach opposing witnesses during trial.

Listen as our authoritative panel reviews their exceptional deposition techniques and provides real-world demonstrations of how they work. The panel will also provide best practices in implementing those techniques when dealing with any deposition with anyone from the everyday adverse witness to the most difficult and evasive witnesses.



  1. Introduction
  2. Exhaustion
  3. Restating/summarizing
  4. Boxing-in
  5. Structuring depositions for difficult and evasive witnesses


The panel will review these and other key issues:

  • What do litigators need to know to improve their exhaustion techniques?
  • How should these deposition best practices be applied when structuring a deposition for an evasive witness?
  • How will these approaches improve counsel’s ability to impeach an opposing witness?
  • What techniques can litigators use to gather the information needed to affect the outcome of a case in their client’s favor?


Michael R. Gordon
Michael R. Gordon

Manatt Phelps & Phillips LLP

Mr. Gordon focuses on complex commercial litigation. He has substantial experience trying cases in state and federal...  |  Read More

John A. Snow, Esq.
John A. Snow, Esq.

Prince Yeates & Geldzahler

Mr. Snow's practice focuses on general civil litigation. He is listed in "The Best Lawyers in America" in...  |  Read More

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