Event Details

Depositions 5 of 5: Questioning Techniques

In the old Hollywood "mobster" movies, the gangsters referred to their lawyers as "mouthpieces." The gangsters always seemed to be worried that someone would "rat them out" or "turn state's evidence" against them. They were concerned that "this someone" would "sing like a canary" to the authorities. Such potential threats were often "rubbed out," not "cancelled." 

There are tried-and-true methods or techniques to get a witness to "sing like a canary." These include the "funneling technique," the "listing technique," the "lima bean routine" of questioning, as well as various others. Unfortunately, these are not usually taught; the only way to learn these has been "the hard way," that is the college of hard knocks. The basics, when executed properly, every time, are what make us professionals. Sign up to learn these fundamental questioning techniques.


*All registrations are assumed to be remote unless otherwise stated. To reserve your seat for the in-person option, please contact Ann Horn at Ann@SonomaCountyBar.org or (707) 542-1190 ext. 100 to transfer your remote registration to in-person. 
For the comfort of our guests, a limited number of in-person seats are available. If you wish to attend in-person, we suggest notifying our office at your earliest convenience to reserve your seat. Walk-ins will be admitted as space allows. In-person registrations expire at the start of the presentation. We do ask that you arrive promptly; otherwise your reserved seat may be given to a walk-in attendee. In-person reservations are non-refundable unless cancelled prior to 3 pm one business day prior to the presentation.
In-person will be at SCBA's new office location: 
3035 Cleveland Ave., Ste. 205
Santa Rosa, CA 95403

If you need assistance registering for this program, please email Reception@SonomaCountyBar.org and we will assist you as soon as possible.

Thank you.


Michael G. Watters

Michael G. Watters
Managing Partner
O’Brien, Watters & Davis, LLP

Mr. Watters is a veteran trial and appellate lawyer. He has tried more than 40 jury trials to verdict, more than 30 court trials to judgment, handled many arbitrations, as well as more than 75 appeals. 

He has taken or defended more than 1000 depositions in a variety of cases including medical malpractice, personal injury, wrongful death, products liability, employment litigation, real estate fraud, fraud in the sale of businesses, partnership disputes, family law, elder financial abuse, probate and trust litigation, etc. 

Mr. Watters has been actively involved in ADR. He was on the AAA Commercial Arbitration panel for many years. He was a Mediator with the American Arbitration Law and Mediation Center. Mike was a long time Settlement Conference Panelist. Michael has also been a court appointed Discovery Referee.

He established a formal litigation training program at his firm and trained more than a dozen local trial attorneys including the first woman hired to do civil litigation in the county, the county’s first woman Superior Court Judge, two Deans of Empire Law School, and several other lawyers who also became Sonoma County Superior Court Judges. 

Michael received his B.S. and M.B.A. from Cal and his J.D. from Hastings. Michael Watters has presented a number of SCBA MCLE programs including topics on the deposition.

Lawyer Referral Service

SCBA can help you find the right lawyer to assist you with your legal issues.
Contact Win Rogers by email or call her at (707) 546-5297 for a referral.