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Deposition Control: Becoming the Authority & Controlling the Conversation 2022 - 6 CLE / 1 E

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Deposition Control: Becoming the Authority & Controlling the Conversation

6 CLE / 1 E - A National Speaker Seminar

Both the novice and experienced will benefit from Sybil’s perspective on the art and science of depositions. She will not present dictates, but will illuminate tactics and styles, to help you fashion or improve your own approach. She will work with you to develop a deposition persona that is uniquely personal and unquestionably successful!


Preparing your witness to succeed

“Best practices” for preparing your witness include the use of documents during preparation and the latest research to help your witness feel comfortable & perform at his or her best.

Drafting & using outlines

While you never want to be tied to your outline, advance

preparation allows you the flexibility to move beyond the outline in a deposition. We’ll review several outline templates to identify the styles that will work best in different circumstances.

Taking & defending depositions

Whether conducting a discovery deposition, a trial deposition, a hybrid or defending your own witness, the fundamentals are crucial. Beyond those basics, though, Sybil provides tips and tricks to elevate your performance. Effective objections when defending a deposition, the objection is your primary tool. This section covers everything—from teaching your witness about depositions to effectively using them to preserve your record.

Expert depositions

The expert has likely been deposed before—explore special considerations for expert depositions including how to set up a Daubert motion, your trial cross-examination, or even increase your chances of settlement.

Identifying your deposition style

Playing to your own strengths will help you achieve your deposition objectives (and feel comfortable while doing so). Identify your own deposition style by examining a showcase of various, successful models.

Deposition technology

The court reporter is an officer of the court. Your ethical interaction with the reporter as well as the proper use of technology, including video, Realtime, and electronic exhibits increase your likelihood of a successful deposition.

Ethical pitfalls to avoid

When there is a transcript, there is room for error. This section reviews recent case law providing deposition guidance and offers advice for avoiding ethical missteps.



Sybil Dunlop is a partner with Greene Espel PLLP in Minneapolis, where she handles complex litigation for local and international clients. As a counselor, she advises Fortune 100 clients through business disputes with contractors, clients, and business partners. As a litigator, Sybil is a passionate advocate with first-chair trial and arbitration experience. She has also represented clients before the Patent Trial and Appeal Board, including the first patent owner to score a complete victory in a CBM proceeding. No matter the situation, Sybil invests in learning each client’s business and works to craft a strategy aimed at achieving identified objectives.

Prior to joining Greene Espel in 2010, Sybil clerked for the Honorable James M. Rosenbaum of the United States District Court for the District of Minnesota. Sybil graduated from Vanderbilt University Law School in 2008, Order of the Coif, where she served as Senior Notes Editor for the Vanderbilt Law Review. Before attending law school, Sybil lived and worked in both Geneva, Switzerland and in Washington, DC, where she was Political Research Deputy for EMILY’s List.

As an active legal scholar and enthusiastic teacher, Sybil writes a monthly column for the Minnesota Lawyer, hosts a recurring webcast series, teaches nationally on federal practice, privilege, legal writing, and implicit bias.

ICLEF • Indiana Continuing Legal Education Forum, Indianapolis, IN • Premier Indiana CLE


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