Deposing Named Plaintiffs in Class Litigation: Leveraging Issues of Adequacy and Commonality

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

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Conducted on Thursday, August 5, 2021

Recorded event now available

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Course Materials

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.


In deposing named plaintiffs, the defense counsel's goal is to uncover evidence showing that the plaintiff cannot adequately represent the interests of the entire class and to identify differences among the named plaintiff and absent class members that demonstrate a lack of commonality within the class.

The named plaintiff's answers to the deposition questions will allow both plaintiff and defense counsel to better prepare for the next steps, depending on counsels' assessment of whether the information obtained strengthens or weakens the adequacy, typicality, and commonality showing.

Listen as our authoritative panel of class litigators discusses effective techniques for taking and defending depositions of named plaintiffs and strategies for using deposition testimony during certification, settlement, and trial.



  1. Timing of deposition
  2. Questioning named plaintiffs and responding to objections
  3. Preparing named plaintiff for deposition and objecting to deposition questions
  4. Using exhibits
  5. Using information obtained from social media
  6. Post-deposition strategies: class certification, settlement, trial


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?


Desai, Reena
Reena I. Desai

Nichols Kaster

Ms. Desai is a litigator who has represented employees in class and collective actions as well as individual...  |  Read More

Hunt, Adam
Adam J. Hunt

Morrison & Foerster

Mr. Hunt is an associate in the Litigation Department of Morrison & Foerster’s New York office. His practice...  |  Read More

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