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Deposition Strategies in Divorce and Custody Cases: Deposing Parties, Lay Witnesses, and Experts

Leveraging Deposition Testimony During Discovery, Settlement, and Trial

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 Tuesday, February 14, 2023

Recorded event now available

or call 1-800-926-7926

This CLE course will prepare family law practitioners to take and defend depositions of parties, lay witnesses, and expert witnesses in divorce and custody cases. The panel will explain tactics for preparing witnesses, outline techniques for effective questioning, and offer strategies for leveraging deposition testimony during discovery, settlement, and trial.


Effective deposition skills are critical to a successful family law practice. Information gained during depositions impacts trial strategy and settlement discussions. Obtaining or protecting critical information during depositions is key to a positive--or negative--case outcome.

Properly preparing deponents, taking control of the dynamics of a deposition, effectively questioning lay and expert witnesses, and strategically raising objections all have a significant impact on the amount and usefulness of information obtained during depositions.

Listen as our authoritative panel of family law attorneys discusses effective witness preparation techniques, advanced questioning methods, and strategies for using deposition testimony during discovery, settlement discussions, and trial.



  1. Planning for depositions
    1. Determining who to depose
    2. Goals of deposition
    3. Seating arrangements, participant personalities, and other "dynamics" considerations
    4. Witness preparation
    5. Document requests
  2. Taking and defending depositions
    1. Questioning witnesses
    2. Raising and responding to objections
    3. Using exhibits
    4. Using information obtained from social media
  3. Post-deposition strategies
    1. Using deposition information during discovery
    2. Using deposition information during settlement discussions and trial


The panel will review these and other key issues:

  • What are the most common challenges family law practitioners face when taking and defending depositions of parties, lay witnesses, and experts?
  • What deposition questioning techniques will maximize the information obtained from witnesses?
  • What strategies are effective when raising and responding to objections during depositions?
  • How can deposition testimony be most effectively used during discovery, settlement, and trial?


Black, Barbra
Barbra I. Black

Managing Partner
The Black Law Group

Ms. Black has been practicing law for over thirty years and is a founding member and the managing partner of The Black...  |  Read More

Pikus, David
David H. Pikus

Bressler Amery & Ross

Mr. Pikus has been actively engaged as a litigator for over three decades in New York and New Jersey. Devoted to...  |  Read More

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