It’s been said that there are as many examples of obstruction as there are lawyers who have taken a deposition. Every plaintiffs’ lawyer who has taken a deposition has run into the overzealous delay tactics, objections, comments, and threats meant to interfere with your inquiries that defense counsel so often employ. Even simple requests such as, “Please tell us what happened,” can result in senseless objections. 

In this 60-minute presentation, Mark Kosieradzki, one of America’s leading deposition experts, arms you with the ammunition you need to smash through the defense’s obstructive tactics. Join Kosieradzki as he demonstrates how to deploy the rules and case law that will help you compel the answers you need–and call for sanctions when the defense still refuses to comply. 

Kosieradzki will cover:

• Initial 30(b)(6) conferral requirements
• Good faith conferral requirements
• No duty to agree
• The responding lawyers' duty to bring a motion under Rule 37
• Timing considerations
• Consequences of failure to appear
• Managing partial preparation scenarios effectively
• Instructions not to answer
• Privilege waiver
• Strategies for dealing with obstructive objections during depositions

30(b)(6) depositions are a valuable tool in any lawyer’s arsenal for discovery. Don’t let the pushback, objections, and defense obstruction keep you from the evidence you need. Join Mark Kosieradzki as he gives you the tools you need to fight back.

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