Deposing Nursing Home Employees and Owners in Neglect and Abuse Cases

Questioning Deponents, Using Demonstrative Exhibits, Raising and Defending Objections, Dealing With Difficult Deponents

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

Conducted on Tuesday, April 9, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will provide medical malpractice and personal injury attorneys with an in-depth analysis of deposition practice in nursing home injury cases. The webinar will discuss best practices for identifying and questioning deponents, videotaping depositions, using demonstrative exhibits, dealing with difficult witnesses, and raising and defending objections.


For attorneys representing victims in nursing home injury cases, the depositions of nursing home employees, owners and corporate representatives are among the most significant events in the case. Depositions allow medical malpractice and personal injury attorneys an opportunity to scrutinize the nursing home's policies and practices to determine if patient care and safety are a priority.

As testimony obtained from the nursing home owner or representative during the deposition binds the nursing home, counsel must consider who to depose, the reason for the deposition, and carefully prepare to maximize their effectiveness during the deposition process. Counsel must think critically and logically about the deposition process to gain testimony that will increase the value of the case. Medical malpractice and personal injury attorneys should consider using strategic moves when deposing nursing home staff and owners, including videotaping the depositions and using demonstrative exhibits such as autopsy reports.

Listen as our expert panel explains the legal and practical considerations for medical malpractice and personal injury attorneys when preparing for and conducting depositions of nursing home staff and owners in nursing home injury cases. The panelists will share useful insights on the strategic use of these depositions at trial and during settlement negotiations.



  1. Purpose of the deposition
    1. Prove the case by gaining admissions of rule violations, causation and damages
    2. Develop a roadmap for adverse examination
    3. Create traps for witnesses
    4. Discredit future defense experts
  2. Techniques and strategies to prepare for and take the deposition
    1. Knowing your goals, the facts, the witnesses, the rules and the damages
    2. Anticipating defenses
    3. Role playing
    4. Objecting and responding to defense objections
    5. Creating traps for evasive or difficult deponents
    6. Do's and don'ts during the deposition


The panel will review these and other key issues:

  • What topics should attorneys explore when questioning nursing home staff and owners during depositions?
  • When and how should attorneys use demonstrative exhibits during depositions of nursing home staff and owners?
  • What are best practices for dealing with difficult deponents?
  • How to effectively question deponents to discredit defense experts
  • What are effective techniques for raising and defending objections during depositions of nursing home staff and owners?


Ayllon, Daisy
Daisy Ayllon

Levin & Perconti

Ms. Ayllon has worked on an array of cases, including a defamation lawsuit, a case involving a mental-health patient...  |  Read More

Bonamarte, Michael
Michael F. Bonamarte, IV

Levin & Perconti

Mr. Bonamarte has been advocating for the rights of the elderly who have been abused and neglected in nursing homes for...  |  Read More

Levin, Steven
Steven M. Levin

Founder and Senior Partner
Levin & Perconti

Mr. Levin is the senior and founding partner of Levin & Perconti, a 25 attorney nationally renowned law firm in...  |  Read More

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