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Deposition Admissions: Maximizing the Number and Force of Admissions in Key Depositions

Creating Streamlined and Simple Narratives in Complex Cases and Sowing Distrust of Opposing Themes

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, April 7, 2022

Recorded event now available

or call 1-800-926-7926

This CLE course posits that the primary goals in a deposition of an opponent’s key witness are the same as effective cross-examination at trial—to frame questions that will either elicit admissions or set up effective impeachment. The program will present a five-step approach for achieving these objectives.


The starting point is to develop an overall narrative and themes of the case. Once those objectives are firmly in mind, the goal for the deposition of a key witness is to figure out how to get the deponent to admit as many of the facts supporting that narrative as possible, or to effectively impeach the deponent who resists or equivocates. The remaining steps are tactical, and will be addressed in detail in the program, but include the structure of the examination, the framing of critical questions, and why to limit the use of open-ended and recap questions. The focus is on fact and expert depositions in complex, high-stakes civil cases, but the program offers guidance broadly applicable to all civil litigation.

The presentation will identify some ancillary benefits of this focused approach on obtaining admissions, as well as why more traditional and widely taught approaches to taking depositions are less effective and less valuable at trial. The panel will include experienced trial lawyers, each of whom will offer their own unique insights into the most effective ways to obtain valuable admissions from key adverse witnesses.

Listen as our esteemed panel addresses how to frame questions that will either elicit admissions or set up effective impeachment.



  1. Form should follow function
  2. Five-part approach to questioning
    1. Theme
    2. Admissions
    3. Achievable
    4. Drafting the right questions
    5. Connecting the dots
  3. Benefits of avoiding open-ended questions
  4. Dealing with obstructionist responses
  5. Preparing for and defending the admission seeking a deposition


The panel will review these and other critical issues:

  • Why the primary goals of a key deposition should be the same as cross-examination at trial.
  • How to maximize the number and force of admissions in a key deposition.
  • The downsides and limited benefits of more traditional approaches to taking depositions.
  • Other benefits of this admissions-focused approach in obtaining successful outcomes at trial or through settlement.


Bloomberg, Mark
Mark H. Bloomberg

Of Counsel
Zuber Lawler

Mr. Bloomberg is an intellectual property litigator. With more than 35 years of experience, he has represented clients...  |  Read More

Cochran, Anthony
Anthony L. Cochran

Smith Gambrell & Russell

Mr. Cochran represents individuals and businesses in a wide variety of matters. He has tried jury trials, bench trials,...  |  Read More

Mais, Joseph
Joseph E. Mais

Perkins Coie

Mr. Mais is a Fellow of the American College of Trial Lawyers who has served as lead counsel in many trials and...  |  Read More

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