Seminar Program - NELA

October 6-7, 2023 Atlanta Marriott Buckhead Hotel
& Conference Center

Defeating Summary Judgment in the Face
of Evolving Defense Tactics

All Times Eastern
Thursday, October 30, 2025
11:00–11:15 a.m.	Welcome & Opening Remarks
11:15 a.m.–12:00 p.m.	The Ground Rules & Deposition Goals in Employment Cases Speakers: Austin D. Skelton & Brooke C. Timmer Our opening session will ensure your deposition begins on solid ground, long before you ever enter the room. Panelists will break down how having a strong understanding of the ground rules in play during depositions and your goals for each deposition can guide the rest of your preparation and final strategy.
12:15–1:15 p.m.	CONCURRENT SESSIONS
	Preparing Your Client for Deposition 101 Speakers: Rachhana T. Srey & Mariyam Hussain Ensuring your client is confident and prepared before their deposition can be the key to your case. Whether it is communicating the ground rules of the deposition, explaining the “day of” procedure, and ensuring your theories and goals are clearly communicated to your client, panelists will share their techniques for effectively preparing your client for their deposition.
	Innovative Techniques for Client Preparation Speakers: Ben Lebsack & Rebecca Peterson-Fisher When dealing with clients or expert witnesses, there may be situations that may require more advanced and innovative techniques. This session will cover innovative techniques that can help you prepare for a variety of clients and witnesses, including those dealing with extensive trauma and those who may have trouble following instructions.
1:30–2:30 p.m.	Defending the Deposition Speaker: Jennifer I. Klar & Stephanie K. Wood Understanding how to effectively defend a deposition is a vital tool for any attorney. Defending the deposition is not merely about understanding the framework for making objections, protecting your client and responding to client behavior, but also about ensuring you are upholding your ethical obligations. Our panelists will share their tips for effectively defending a deposition, while protecting your attorney-client privilege and work product immunity.
3:15–5:15 p.m.	Small Group Workshops Attendees will break into small group workshops (less than 10) to practice skills learned during lectures and receive feedback from experienced facilitators. Attendees will have access to the small group exercises in advance. While not required, attendees can complete the written exercises in advance to make the most out of their workshop experience. Attendees are encouraged to bring their own case or use a provided sample case packet. Small group workshops will be divided by skill level.
Friday, October 31, 2025
11:00 a.m.–12:00 p.m.	Working Your Depositions into an Effective Discovery Plan Speakers: Megan S. Goddard & David L. Lee Carefully planning your discovery and coordinating your depositions with the other discovery tools at your disposal is critical to successful litigation. Our faculty will share strategies for determining what discovery you might need in any particular case and how that discovery should be conducted. They also will explore strategies and techniques for developing potential evidence to support (or to undermine) your and your opponent's contentions; developing credibility evidence for (and against) both sides, including evidence that might either explain or exploit an apparent inconsistency; and converting your potential evidence into topics to explore during discovery.
12:15–1:15 p.m.	CONCURRENT SESSIONS
	The Basics of Taking a Deposition Speakers: Christine T. Elzer & Andrew Lacy Now that you have developed your discovery plan, you need to hone your skills at the deposition table (or Zoom room!). Our panelists will cover cross-examination style questioning to box your adverse deponent into giving you helpful admissions and provide tools for determining what admissions you typically will seek from different deponents, including from a corporate representative (pursuant to a 30(b)(6). Additionally, panelists will share insights on how to avoid framing errors that lead to objections and other interruptions, and how to effectively respond to typical deposition objections.
	Advanced Deposition Taking Techniques Speakers: Kathleen M. Cahill & Ben Lebsack This advanced session will go beyond the basics of taking a deposition to hone your skills, to help more advanced practitioners develop creative approaches, planning, techniques and handling surprises and difficult witnesses. This session will cover planning considerations, strategies and techniques for responding to evasive, non-responsive, forgetful, and uncertain answers; attacking the accuracy and/or credibility of a harmful answer; undermining opinions and conclusions; and responding to inconsistent and implausible answers.
2:00–5:00 p.m.	Small Group Workshops Attendees will break into small group workshops (less than 10) to practice skills learned during lectures and receive feedback from experienced facilitators. Attendees will have access to the small group exercises in advance. While not required, attendees can complete the written exercises in advance to make the most out of their workshop experience. Attendees are encouraged to bring their own case or use a provided sample case packet. Small group workshops will be divided by skill level.