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Preparing For, Taking, and Defending Depositions of Class Representatives

Deposition Logistics; Key Topics; Questioning Techniques; Post-Deposition Strategies

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, October 26, 2023

Recorded event now available

or call 1-800-926-7926

This CLE course will prepare defense counsel to depose and plaintiffs' counsel to defend depositions of class representatives in class litigation. The panel will outline techniques for effectively preparing or questioning class representatives and offer strategies to leverage deposition testimony during certification, settlement, and trial.


In deposing class representatives, 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 class representative and absent class members that demonstrate a lack of commonality within the class. Oftentimes in consumer protection cases, the class representative will make other significant concessions.

The class representative’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 class representatives and strategies for using deposition testimony during certification, settlement, and trial.



  1. Qualities of a compelling class representative
  2. Deposition timing
  3. Deposition location
  4. Preparing the class representative
  5. Preparing to depose the class representative
  6. Deposition strategies
  7. 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?


Biderman, David
David T. Biderman

Perkins Coie

Mr. Biderman focuses his practice on mass tort litigation and consumer class actions. He heads the firm's Mass...  |  Read More

Davidson, Stuart
Stuart A. Davidson

Robbins Geller Rudman & Dowd

Mr. Davidson’s practice focuses on complex consumer class actions, including cases involving deceptive and unfair...  |  Read More

Halfon, Avery
Avery Halfon

Lieff Cabraser Heimann & Bernstein

Mr. Halfon is an associate in Lieff Cabraser’s New York office, where he represents victims of corporate greed,...  |  Read More

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