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DEPOSITION SKILLS

Henry L. Hecht, Peter Gruenberger, and other members of The Hecht Training Group offer practical one- to-two day workshops that combine simulations, lectures, and demonstrations to teach deposition techniques at different skill levels.

FORMAT

The workshops stress the "learning-by-doing" method of skills training. Working in small groups, participants prepare, depose, and defend a witness in simulated depositions. After each performance, the participants are critiqued by a faculty, consisting of experienced attorneys from your office working with the instructor. In addition, performances can be videotaped for one-on-one review and critique.

During the workshop, the simulated depositions are interspersed with faculty demonstrations on witness preparation, examination and defense techniques, and the uses of depositions at trial.

The Hecht Training Group offers three separate depositions skills programs. A customized one-day course is presented for less experienced lawyers or summer associates. We also offer a one-to-two day more sophisticated program for more experienced associates. For associates who have taken either of the two lay witness deposition programs, a program on Depositions of Experts, described separately in the Course Offerings, is available. Before the workshops, it is recommended that at least one lecture be given by the in-house faculty on deposition skills, for which a speaker's outline is provided in the faculty teaching notes.

There is no limit on the number of participants for the workshops; however, the number is contingent upon the number of available in-house faculty. To train the attorneys who serve as in-house faculty in the techniques of observation and critique, a faculty training session precedes the workshop.

MATERIALS

In advance of the program, participants receive detailed instructions, a case file, including pleadings, witness statements, documents produced in the litigation, experts' damage reports, and jury instructions, and background resource materials on deposition skills, including chapters from Mr. Hecht's book Effective Depositions (ABA 1997). In addition, in-house faculty members receive teaching notes outlining the skills to be taught, the lectures to be given, and the demonstrations to be performed during the program. A case file often used is Scoops v. Business-Aide, Inc. 4th ed. (2007), written by Mr. Hecht. The case involves claims of misrepresentation and breach of warranty in the sale of computer hardware and software to a small business. A demonstration DVD based on the Scoops case file is also available. If desired, other mock case files may be used.

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