
10,000 Depositions Later Podcast
Claim This Podcastby Jim Garrity
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Podcast Overview
<p><span>From Jim Garrity, the country’s leading deposition expert, comes this podcast for hardcore litigators. The subject? Taking and defending depositions.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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: “</span>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.”</p><p><br></p><p>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.</p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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. </span></p>
Language
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Publishing Since
10/17/2020
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Recent Episodes

May 8, 2026
Episode 172: Second-Order Knowledge Examinations
<p>In this episode, Jim talks about the value of "second-order" examinations - asking deponents not only what they know, but what others know (and what others know that still others know, which is a form of third-order knowledge). It's an incredibly valuable tool for ensuring you fully understand the actors, documents, and events in your cases. Garrity explains why witnesses will talk more freely about what others know than about what they themselves know, and wraps up with practice tips for litigators who are either taking - or defending against - second-order knowledge examinations.</p><p>As always, thanks for listening!</p>

April 24, 2026
Episode 171: Examination Techniques - The Reid Technique
<p>In this final episode of our cross-examination series, Jim Garrity turns to the Reid Technique, the interrogation system developed in the 1940s for American law enforcement. Though the method has drawn serious criticism and been linked to false confessions, many of its individual components quietly appear in depositions, administrative hearings, and arbitrations every day, often deployed by lawyers who have never heard the name John Reid.</p><p>We break the technique into three "movements" civil litigators will recognize: the non-accusatory, warm opening that triggers reciprocity; confrontation and theme development, where a sympathetic narrative conceals a damaging concession; and the compound question that forces a false binary. Along the way, we cover how to prepare witnesses to recognize tonal shifts, resist softened mischaracterizations, and reject false either/or options. Finally, Jim explains how taking attorneys can ethically deploy these tools themselves.</p>

April 9, 2026
Episode 170 - Examination Techniques: The Reptile Method
<p>In this third installment of our series on examination techniques, Jim Garrity dives into the so-called Reptile Method, <span>developed by jury consultant David Ball and plaintiff’s attorney Don Keenan, and explained in their 2009 book Reptile: The 2009 Manual of the Plaintiff’s Revolution. It's long been a controversial approach because, some say, it's a disguised version of Golden Rule arguments that are generally forbidden in most jurisdictions. But wh</span>ether you’re on the plaintiff side looking to deploy it or the defense side looking to neutralize it, you need to understand how the three-stage sequence works, and where it’s vulnerable.</p><p>SHOW NOTES</p><p>https://columbialawreview.org/content/shadow-tort-law-lessons-from-the-reptile/ (Columbia University law review article on "The Reptile" method)</p><p>https://lewisbrisbois.com/insights/clientalerts/the-reptile-theory-in-practice (defense firm blog on the Reptile Theory)</p><p>https://imslegal.com/articles/reptile-brain-strategy-why-use-it-how-counter-it (jury consulting firm article on the Reptile Method)</p>
173 total episodes available with 12 transcripts
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- What is 10,000 Depositions Later Podcast?
<p><span>From Jim Garrity, the country’s leading deposition expert, comes this podcast for hardcore litigators. The subject? Taking and defending depositions.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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: “</span>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.”</p><p><br></p><p>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.</p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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.</span></p><p><br></p><p><span>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. </span></p> - How often does this podcast release new episodes?
This podcast updates weekly.
- Where can I listen to this podcast?
This podcast is available on 9 platforms including Apple Podcasts, Spotify, and more. You can also use the RSS feed directly.
- Does this podcast accept guests?
Yes, this podcast regularly features guests.
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