Deposing Named Plaintiffs in Class Litigation: Leveraging Issues of Adequacy and Commonality
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will prepare defense counsel to depose and plaintiffs' counsel to defend depositions of named plaintiffs in class litigation. The panel will outline techniques for effectively preparing or questioning named plaintiffs and offer strategies to leverage deposition testimony during certification, settlement, and trial.
Outline
- Timing of deposition
- Questioning named plaintiffs and responding to objections
- Preparing named plaintiff for deposition and objecting to deposition questions
- Using exhibits
- Using information obtained from social media
- Post-deposition strategies: class certification, settlement, trial
Benefits
The panel will review these and other key issues:
- What types of questions and questioning techniques will maximize the information obtained from named plaintiffs during depositions?
- What are effective ways to prepare the plaintiff for their deposition?
- What are some techniques for defending a named plaintiff deposition?
- How are class litigators incorporating social media into the deposition process?
- How can deposition testimony be used during class certification, settlement, and trial?
Faculty

Reena I. Desai
Partner
Nichols Kaster
Ms. Desai is a litigator who has represented employees in class and collective actions as well as individual... | Read More
Ms. Desai is a litigator who has represented employees in class and collective actions as well as individual cases. She has dedicated the majority of her career to helping thousands of employees recover unpaid wages, and has also handled cases involving race and disability discrimination. Ms. Desai is a frequent author and lecturer on employment law and litigation strategy.
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Adam J. Hunt
Attorney
Morrison & Foerster
Mr. Hunt is an associate in the Litigation Department of Morrison & Foerster’s New York office. His practice... | Read More
Mr. Hunt is an associate in the Litigation Department of Morrison & Foerster’s New York office. His practice focuses on complex litigation, with an emphasis on class action and commercial litigation.
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