10,000 Depositions Later Podcast podcast

10,000 Depositions Later Podcast

From Jim Garrity, the country’s leading deposition expert, comes this podcast for hardcore litigators. The subject? Taking and defending depositions. Each episode is a one-topic, mini field guide, meant to educate and inform trial lawyers looking for world-class deposition strategies and tactics. Garrity includes a general discussion of the topic, specific insights and guidance, questions to ponder, and case citations to support his observations. They’re jam-packed with immediately useful advice and guidance. Garrity has appeared as lead trial counsel in more than two thousand federal and state civil cases. His personal deposition experience now far exceeds the 10,000 mentioned in the title. (For business reasons, his publisher did not want him to update the title number.) He’s been up against the best litigators at hundreds of firms, from the nation’s largest to sole practitioners, and there’s literally no tactic, trick, variation or strategy he hasn’t seen hundreds of times. Indeed, one federal judge, commenting in open court, observed that Garrity “has pulled multiple rabbits out of multiple hats,” meaning he wins cases against inconceivable odds. How? Because of his extraordinary deposition skills. Depositions are the decisive factor in nearly all settlements and trials. You cannot achieve excellent outcomes if you cannot prevail in depositions. Garrity is famous for his simple, keen observation: “Depositions are the new trial.”  Why? Because almost none of your witnesses will ever testify anywhere other than in a deposition. Yale University Professor Marc Galanter, in his law review article titled “The Disappearance of Civil Trials in the United States,” opened with this shocking statistic: “Since the 1930’s, the proportion of civil cases concluded at trial has declined from about 20% to below 2% in the federal courts and below 1% in state courts.” So depositions are in fact the new trial. Except for a tiny fraction of your cases, the court reporter's office is the only place where your testimony will be taken and heard. And that is where your case will be won or lost. You can’t afford anything less than expert-level skill in the deposition arts. This podcast, based on Garrity's best-selling book,10,000 Deposition Later: The Premier Litigation Guide for Superior Deposition Practice (3d Ed., 450 pp.; Amazon, Barnes & Noble), is a litigator’s dream, not only revealing cutting-edge techniques and procedures, but telling you how to combine them creatively and successfully. Learn how to gain advantage at every step. Learn the path to victory and learn where the landmines are along that path. Discover the legitimate (and illegitimate) tactics opponents use that you’ve never seen before. The podcast is heavy on insights you can immediately implement. Regardless of your years of experience, the episodes will provide an astonishing advantage. And each episode contains citation to court decisions to support Garrity’s advice. His expert guidance begins with the moment you first conceive plans to capture testimony – whether by deposition, affidavit or EUO (and he’ll tell you how to figure out which to use and when). Most importantly, he explains what he does and why. No part of the deposition process will be overlooked – forming the battle plan, scheduling, dealing with reporters, taking depositions, defending them, prepping witnesses to make them invincible, handling every conceivable type of witness, making objections, dealing with obstructive lawyers, and tips pertinent to deposition transcripts, from the moment of receipt through trial. If you’re serious about developing killer deposition skill sets, subscribe to this podcast so that you receive each episode automatically in your feet as they are uploaded. 

From Jim Garrity, the country’s leading deposition expert, comes this podcast for hardcore litigators. The subject? Taking and defending depositions. Each episode is a one-topic, mini field guide, meant to educate and inform trial lawyers looking for world-class deposition strategies and tactics. Garrity includes a general discussion of the topic, specific insights and guidance, questions to ponder, and case citations to support his observations. They’re jam-packed with immediately useful advice and guidance. Garrity has appeared as lead trial counsel in more than two thousand federal and state civil cases. His personal deposition experience now far exceeds the 10,000 mentioned in the title. (For business reasons, his publisher did not want him to update the title number.) He’s been up against the best litigators at hundreds of firms, from the nation’s largest to sole practitioners, and there’s literally no tactic, trick, variation or strategy he hasn’t seen hundreds of times. Indeed, one federal judge, commenting in open court, observed that Garrity “has pulled multiple rabbits out of multiple hats,” meaning he wins cases against inconceivable odds. How? Because of his extraordinary deposition skills. Depositions are the decisive factor in nearly all settlements and trials. You cannot achieve excellent outcomes if you cannot prevail in depositions. Garrity is famous for his simple, keen observation: “Depositions are the new trial.”  Why? Because almost none of your witnesses will ever testify anywhere other than in a deposition. Yale University Professor Marc Galanter, in his law review article titled “The Disappearance of Civil Trials in the United States,” opened with this shocking statistic: “Since the 1930’s, the proportion of civil cases concluded at trial has declined from about 20% to below 2% in the federal courts and below 1% in state courts.” So depositions are in fact the new trial. Except for a tiny fraction of your cases, the court reporter's office is the only place where your testimony will be taken and heard. And that is where your case will be won or lost. You can’t afford anything less than expert-level skill in the deposition arts. This podcast, based on Garrity's best-selling book,10,000 Deposition Later: The Premier Litigation Guide for Superior Deposition Practice (3d Ed., 450 pp.; Amazon, Barnes & Noble), is a litigator’s dream, not only revealing cutting-edge techniques and procedures, but telling you how to combine them creatively and successfully. Learn how to gain advantage at every step. Learn the path to victory and learn where the landmines are along that path. Discover the legitimate (and illegitimate) tactics opponents use that you’ve never seen before. The podcast is heavy on insights you can immediately implement. Regardless of your years of experience, the episodes will provide an astonishing advantage. And each episode contains citation to court decisions to support Garrity’s advice. His expert guidance begins with the moment you first conceive plans to capture testimony – whether by deposition, affidavit or EUO (and he’ll tell you how to figure out which to use and when). Most importantly, he explains what he does and why. No part of the deposition process will be overlooked – forming the battle plan, scheduling, dealing with reporters, taking depositions, defending them, prepping witnesses to make them invincible, handling every conceivable type of witness, making objections, dealing with obstructive lawyers, and tips pertinent to deposition transcripts, from the moment of receipt through trial. If you’re serious about developing killer deposition skill sets, subscribe to this podcast so that you receive each episode automatically in your feet as they are uploaded. 

 

#165

Episode 164 - In-Person Depositions Are Making a Comeback

They're baaaaack! In-person depositions, that is. In this episode, Jim Garrity discuss... more

11 Nov 2025

15 MINS

15:19

11 Nov 2025


#164

Episode 163: Lessons from the Front Lines - Pronoun Perils: In 30(b)(6) Depos, “I” is the Entity, No...

When a 30(b)(6) representative is deposed, the testimony is that of the organization, not ... more

08 Oct 2025

11 MINS

11:10

08 Oct 2025


#163

Episode 162 - Your Mute Button is Career Insurance

In this episode, Jim Garrity uses a pending bar disciplinary proceeding against a Florida ... more

27 Sep 2025

08 MINS

08:49

27 Sep 2025


#162

Episode 161: Unfinished Testimony - Can You Use That Partial Transcript?

Today, Jim Garrity examines a critical issue in trial practice: whether an incomplete depo... more

11 Sep 2025

16 MINS

16:09

11 Sep 2025


#161

Episode 160 - Depo Case Roundup for the Week of August 25, 2025

This week’s roundup spotlights four brand-new deposition rulings from across the country. ... more

23 Aug 2025

18 MINS

18:27

23 Aug 2025


#160

Episode 159 - Lessons from the Front Lines: Budget-Friendly Depositions: Using a Videographer to Tap...

Are deposition expenses busting your budget? In this episode, Jim Garrity spotlights a cle... more

06 Aug 2025

12 MINS

12:41

06 Aug 2025


#159

Episode 158 - Using Videotaped Deposition Clips in Openings and Closings

In this episode, Jim Garrity argues for more frequent videotaping of depositions, especial... more

02 Jul 2025

13 MINS

13:33

02 Jul 2025


#158

Episode 157: Lessons from the Front Lines -Pitfalls for Plaintiffs Who Want to Appear Remotely for D...

Now that the pandemic is fading from our memories, courts are showing a renewed willingnes... more

23 Jun 2025

19 MINS

19:07

23 Jun 2025


#157

Episode 156 -Leveraging Device Demonstrations In Depositions: Lessons From The Uber Litigation

Traditionally, litigators seeking to understand an individual's or organization's ... more

23 May 2025

17 MINS

17:35

23 May 2025


#156

Episode 155 - Deposition Case Roundup for the Week of May 12, 2025

Today’s episode showcases four new deposition-related rulings, including one that makes a ... more

14 May 2025

14 MINS

14:06

14 May 2025


#155

Episode 154 - Do You Know What AI Can Do For Your Deposition Practice?

If you haven't already deeply integrated AI into your deposition practice, buckle up! ... more

24 Apr 2025

23 MINS

23:14

24 Apr 2025


#154

Episode 153 - Deposition Case Roundup for the Week of April 2025

In this episode, Jim Garrity highlights three brand new deposition-related court rulings. ... more

12 Apr 2025

22 MINS

22:50

12 Apr 2025


#153

Episode 152 - Deposition Case Roundup - March 20, 2025

Our roundup episodes summarize brand-new, deposition-related court rulings from around the... more

19 Mar 2025

17 MINS

17:06

19 Mar 2025


#152

Episode 151 - Lessons from the Front Lines: Using Deposition Transcripts From One Case as Affidavits...

In this episode, Jim Garrity spotlights a new ruling on a little-known but powerful tool: ... more

04 Mar 2025

10 MINS

10:40

04 Mar 2025


#151

Episode 150 -The Role of Lawyer-Deponent Proximity, and Signifiers of Authority, in Deponent Coopera...

In this episode, Jim Garrity applies lessons from a well-known study - on the factors that... more

11 Feb 2025

15 MINS

15:10

11 Feb 2025


#150

Episode 149 - "Argumentative" Examinations: Speech Masquerading As Questions

In this episode, Jim Garrity talks about a tactic of some examining lawyers that should, b... more

31 Jan 2025

10 MINS

10:33

31 Jan 2025


#149

Episode 148 - Revisiting the Problem of Examiners Who Interrupt Your Deponents' Answers

Today Jim Garrity revisits the headaches caused by examining lawyers who frequently interr... more

04 Jan 2025

16 MINS

16:39

04 Jan 2025


#148

Episode 147 - Going Off the Record While The Deponent Reads Documents? Here’s Why You Shouldn’t.

Some examiners will mark a voluminous document as an exhibit and then declare that "we... more

20 Dec 2024

14 MINS

14:32

20 Dec 2024


#147

Episode 146 - Thorny Hedges: Linguistic Qualifiers (I Think, I Feel, I Believe) That Weaken Testimon...

In this episode, Jim talks about the habit of some deponents of qualifying their answers b... more

02 Dec 2024

17 MINS

17:03

02 Dec 2024


#146

Episode 145 - A Catchall Objection for Unusual Deposition Situations

Have you ever been in a deposition and noticed something improper and prejudicial, but cou... more

15 Nov 2024

10 MINS

10:16

15 Nov 2024


#145

Episode 144 - Narrative Objections Aren’t Necessarily “Speaking Objections” or Coaching

Today Jim Garrity tackles the topic of narrative objections, which are objections that go ... more

06 Nov 2024

21 MINS

21:07

06 Nov 2024


#144

Episode 143 - Depo Case Digest for the week of July 29, 2024

Today's roundup of new deposition-related cases focuses on four rulings. One offers a ... more

31 Jul 2024

17 MINS

17:29

31 Jul 2024


#143

Episode 142 - Deposition Protocol Stipulations

In this episode, Jim Garrity discusses deposition protocol stipulations, which are agreeme... more

17 Jul 2024

17 MINS

17:33

17 Jul 2024


#142

Episode 141 - Depo Case Digest for the Week of July 5, 2024

Our depo case digest episodes present a fast roundup of new deposition-related rulings nat... more

08 Jul 2024

18 MINS

18:05

08 Jul 2024


#141

Episode 140 -Depo Case Digest: (1) OK to Make Pre-Depo Demand for 30(b)(6) Designee Names (2) Courts...

As a result of listener requests, today we add a new kind of show—the Depo Digest episode—... more

22 Jun 2024

08 MINS

08:52

22 Jun 2024