Tuesday, May 31, 2022 from 5:05 PM to 6:00 PM MDT
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Bo Donegan 
Colorado Defense Lawyers Association 

Depositions for Defense Lawyers 

Presented by: Hon. John W. Madden, IV (ret.) 

Tuesday May 31, 5:05-6:00 pm

Applied for .25 ethics and .75 general CLE / CDLA Members ONLY please


The presentation is aimed toward attorneys with a broad range of experience with depositions—from attorneys who have little to no experience up to attorneys with extensive experience.

The presentation initially reviews the rules of civil procedure that apply to and control the deposition process: Rules 30, 32, and 37.

The presentation reviews aspects of Rule 30 in detail, including:

  • when it is permissible to instruct a witness not to answer a question,
  • when a deposition may be suspended or terminated by an attorney,
  • possible sanctions for improper conduct,
  • how depositions are to be conducted, and
  • objections made at depositions.

The presentation also reviews aspects of Rule 37 in some detail, including:

  • moving to compel an answer to a deposition question,
  • required procedural steps, and
  • sanctions.

The presentation then moves to a more detailed examination of deposition objections, including discussion of how:

  • objections should be stated,
  • the rationale behind objecting,
  • improper objections, and
  • responding to objections.

Part of the discussion includes an analysis of the classic deposition objection: “form of the question” versus what the rules actually require.

Next, the presentation provides suggestions and tips on how to make the deposition process more productive. The suggestions and tips are organized around an analysis of the goals of an effective deposition:

  • learning information,
  • preparing for trial, and
  • improving your negotiating position.

The related discussion provides specific recommendations regarding:

  • preparation,
  • starting a deposition,
  • conducting the initial (direct) examination,
  • dealing with difficult witnesses,
  • making a record, exhibits,
  • defending a deposition,
  • cross-examination, and
  • re-direct examination.

The presentation does include video clips of improper, ineffective, and even unethical depositions used to illustrate how depositions should not be conducted—as well as a summary hundreds of thousands of dollars of sanctions that were imposed on one of the parties. (This portion, which involves ethics issues, takes 15 minutes of the presentation.)

Finally, the presentation finishes with constructive suggestions on how to use deposition transcripts at a trial.

To Register for the Webinar, Click Here