Anatomy of a Deposition
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The pre-trial deposition stage is a critical point in any litigation. Indeed many personal injury and commercial cases are either won or lost during the deposition phase. Our panel of experts provides practical guidance, while teaching basic deposition skills, techniques for handling commonly encountered problems, how to use depositions at trial and how to seek rulings from a trial judge. A demonstration of how to conduct a deposition is also re-enacted.
Some of the specific issues addressed include:
- How to control a witness
- Dealing with evasive witnesses
- How to discover and authenticate documents for trial
- What objections can be raised
- When to prevent a witness from answering
- What to do when your witness volunteers information
- How to cut your losses in light of unexpectedly damaging testimony
- How to use depositions at trial to impeach witnesses, introduce testimony of absentee witnesses and place exhibits into evidence
Jay G. Safer, Esq.
Jay G. Safer is a partner in Locke Lord Bissell & Liddell's New York office and has experience
handling complex litigation and arbitration in the United States and abroad. He represents
clients in matters concerning contracts, antitrust, securities, RICO, banking, qui tam, international
litigation and arbitration, including application of the New York Convention and enforcement of
foreign judgments and arbitration awards, insurance, construction, real estate, employment,
media, product liability, health care, professional ethics, financial, constitutional and regulatory
issues. He also counsels clients on commercial matters, including protection and preventive
measures, creation of risk litigation plans, pre-litigation analysis, e-discovery, e-readiness, esignature/
e-sign, document retention policies, and electronic records. Jay was appointed to serve
on the Planning Committee for the Judicial Conference of the U.S. Court of Appeals for the
Second Circuit, which he attended with the Judges of the Second Circuit. Jay was appointed by
Chief Judge Judith S. Kaye to serve on a Special Commission on the Future of the New
York State Courts. The Commission is composed of lawyers, civic leaders, government and
private sector representatives, academicians, and sitting and former trial and appellate court
judges. The Commission's charge is to redesign the state's trial court structure.
Jay is the Past Chair of the 2,000 member Federal & Commercial Litigation Section of the New
York State Bar Association and is the Co-Chair of its Federal Judiciary Committee.
Jay has served as a lecturer on panels and a member of committees with judges and attorneys
discussing a wide range of civil litigation issues, international arbitration and litigation skills,
including cross examination for the National Institute for Trial Advocacy, professional ethics, ediscovery,
e-signature and e-records.
Jay is a member of The Sedona Conference Working Group on Electronic Document Retention
and Production (WG1) and The Sedona Conference Working Group on International Electronic
Information Management, Discovery and Disclosure (WG6). Jay is a member of the Advisory
Board of the Institute for Transnational Arbitration (ITA).
Columbia University,J.D., 1971
Vanderbilt University, B.A., 1968
New York, 1972
u.s. Supreme Court
New York State Court
U.S. Court of Appeals (2nd Circuit)
U.S. Court of Appeals (3rd Circuit)
U.S. Court of Appeals (11 th Circuit)
U.S. District Court, S.D. New York
U.S. District Court, E.D. New York
U.S. District Court, N.D. New York
U.S. District Court, N.D. Illinois
U.S. District Court, Connecticut
John Halebian, a named partner with the firm, graduated from Georgetown University
(undergraduate) and Villanova Law School where he served on the Law Review as a Case and
Comments Editor and as Editor-in-Chief of The Docket, the law school newspaper.
Since graduating from law school, he has specialized in federal and state corporate and
commercial litigation with an emphasis on class actions and securities litigation. Earlier in his legal
career, Mr. Halebian had primary responsibility for handling numerous complex commercial
litigations and federal securities class actions that involved the defense of lawyers and accountants, and
officers and directors of public companies. Several of these litigations involved jury and bench trials.
Subsequently, Mr. Halebian’s practice concentrated on representing shareholders in securities class
action and shareholder derivative litigation and he has continued to handle numerous large complex
corporate and commercial litigations. Mr. Halebian has served as lead or co-lead counsel or as a member
of an executive or steering committee in numerous class action shareholder litigations around the country
that were successfully prosecuted to conclusion. In 2002, Mr. Halebian was appointed to the Executive
Committee of the Global Crossing Securities Litigation in the Southern District of New York, which
was settled for approximately $450 million. More recently, Mr. Halebian has been appointed as lead
counsel or a member of an executive committee in several nationwide wage and hour class actions
that have led to significant settlements or are still pending.
Mr. Halebian has also prosecuted, defended and tried to conclusion numerous complex
commercial and securities fraud litigations on behalf of individual claimants and companies before the
New York Stock Exchange the National Association of Securities Dealers and the American
Arbitration Association. These actions generally involved brokerage customer claims of churning or
Admitted: 1978, New York; United States Supreme Court; U.S. Court of Appeals, Second,
Third, Eighth and Ninth Circuits and U.S. District Court, Southern and Eastern Districts of New York.
Member: The Association of the Bar of the City of New York; American Bar Association; Federal Bar
Council; and the American Association for Justice.
Graduate of New York Law School – 1983
Admitted to the New York State Bar, the United States District Courts for the Southern
and Eastern Districts – 1984
Mr. Burke has over 20 years experience as a personal injury and medical malpractice
trial lawyer, with a record of many multi-million dollar verdicts and settlements. As
counsel to Kelner and Kelner, Mr. Burke represents victims in personal injury, wrongful
death and medical malpractice cases.
Douglas R. Halstrom, Esq.
Mr. Halstrom has been with the Firm since his admission to the Bar in 1991. His practice concentrates in the defense of architects and engineers professional liability claims, as well as lawyers and accountants malpractice claims.
He has also handled various commercial matters and contractual disputes on behalf of owners, general contractors, construction managers and design professionals on both the plaintiff’s and the defendant’s side.
Mr. Halstrom’s background includes extensive litigation experience in the Courts of New York and New Jersey on both the trial and appellate levels. He received his Juris Doctorate from St. Louis University School of Law in 1990.
He is admitted to practice before the Courts of the States of New York and New Jersey, the United States District Courts for the Southern and Eastern Districts of New York and the District of New Jersey, and the United States Court of Appeals for the Third Circuit.