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Courses/Litigation, Trial & Dispute Resolution/Litigation

Mastering Pre-Trial Tactics Part 3: Successful Discovery Techniques & Importance of Good Deposition

Transform your litigation strategy with expert techniques for effective discovery and high-impact depositions.

Created byNYS Academy of Trial Lawyers
BeginnerUpdated Oct 7, 2026
Mastering Pre-Trial Tactics Part 3: Successful Discovery Techniques & Importance of Good Deposition

What You'll Learn

check_circleApply effective techniques for drafting and serving discovery demands
check_circleAnalyze the role of depositions in building a case for summary judgment
check_circleEvaluate strategies for managing discovery disputes and motions to compel
check_circleExecute systematic deposition preparation using outlines and exhibit organization

About This Course

Join us for part three of this five-part series on the skills you need to win your case before you even step into the courtroom.

Andrew Smiley will discuss everything you need to know about successful discovery techniques and the importance of a good deposition.

This course examines the critical pretrial phase of litigation, focusing on the strategic use of discovery and depositions to posture cases for successful resolution. It covers the essential steps for initiating discovery, including filing for preliminary conferences, serving demands for bills of particulars, and obtaining insurance information.

The material details the importance of thorough deposition preparation, including the use of outlines, exhibit management, and the tactical handling of objections. It also addresses the necessity of ongoing discovery, the role of expert input in shaping demands, and the use of deposition testimony to support motion practice and trial preparation.

Topics Covered:

  • Preliminary conference and discovery scheduling
  • Demand for bill of particulars
  • Insurance coverage disclosure requirements
  • Strategic deposition preparation and outlines
  • Authentication of evidence during depositions
  • Handling discovery disputes and motions to compel
  • Supplemental discovery and amended bills of particulars
  • Management of non-party subpoenas

Your Instructors

NYS Academy of Trial Lawyers
NYS Academy of Trial Lawyers
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The NYS Academy of Trial Lawyers is the largest statewide trial bar in the US with 5,700+ lawyer and judge members. We are committed to protecting, preserving and enhancing the civil justice system. Our highly acclaimed CLE programming features extraordinary presenters covering the most timely and important topics.

Andrew J. Smiley, Esq.
Andrew J. Smiley, Esq.

Attorney at Smiley & Smiley LLP

Andrew is the lead trial attorney for Smiley & Smiley, where his practice focuses on significant personal injury, medical malpractice and wrongful death. Andrew is a graduate of Brooklyn Law School. He served as Academy President in 2017–2018 and is also a Past President & Board Member of the New York City Trial Lawyers Alliance. He hosts The Mentor, Esq., a podcast for lawyers.

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Frequently Asked Questions

We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.

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