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Named Plaintiff Depositions in Employment Class Actions: Best Practices for Plaintiff and Defense Counsel

Witness Preparation, Developing Effective Exhibits, Using Social Media, Responding to Objections

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 Wednesday, January 17, 2024

Recorded event now available

or call 1-800-926-7926

This CLE course will prepare litigators to depose or defend depositions of named plaintiffs in class and collective actions. The panel will outline techniques for adequately preparing and questioning named plaintiffs and offer strategies to leverage deposition testimony during certification, settlement, and trial.


When deposing named plaintiffs in employment class or collective actions, the parties have opposing goals. Defense counsel aims to uncover evidence showing that the plaintiff is unable to represent the interests of the entire class of employees adequately and to identify differences between the named plaintiff and the proposed class in an attempt to defeat commonality and typicality. Plaintiff's counsel aims to bolster the alleged facts and demonstrate how the named plaintiffs share common legal and factual issues with and can adequately represent the proposed class.

The named plaintiff's answers to the deposition questions will allow both counsel to better prepare for the next steps in the case by assessing strengths or weaknesses as they relate to adequacy, typicality, and commonality.

Listen as our authoritative panel of employment class litigators discusses practical techniques for taking and defending depositions of named plaintiffs in employment class or collective actions 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 questions
  4. Using exhibits
  5. Using information obtained from social media


The panel will review these and other principal issues:

  • What types of questions and questioning techniques will maximize the information obtained from named plaintiffs during depositions?
  • What strategies are effective when responding to objections during depositions of named plaintiffs?
  • What are the most effective ways for counsel to raise objections to questions during the deposition of a named plaintiff?
  • How are class litigators incorporating social media into the deposition process?
  • How can deposition testimony be most effectively used during class certification, settlement, and trial?


Ojserkis, Rebecca
Rebecca Ojserkis

Cohen Milstein Sellers & Toll

Ms. Ojserkis is an Associate in Cohen Milstein’s Civil Rights & Employment Litigation practice, where...  |  Read More

Pope, John
John Houston Pope

Epstein Becker & Green

Mr. Pope is a Member of the Firm in the Employee Benefits, Litigation, and Employment, Labor & Workforce Management...  |  Read More

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