** CA Litigation Bundle (Civil) **

Audio program! (check our CLE Programs page for live versions)

Our California litigation bundle includes several of our most popular litigation courses. You’ll learn about taking and defending depositions, jury selection, handling expert witnesses, and the details of civil court procedure in federal and superior court and more!

Save $826 when you order the bundle!  (If you were to purchase each program separately, the cost would be $2125)

Expert Witnesses: The Dos, Don’ts, and Maybe’s (2013)
Federal Court Boot Camp (2019)
Jury Selection: What Happens When …? (2015)
Depos: How to Master the Deposition (2018)
Superior Court Boot Camp (2019)

A few of the above programs were recorded in more than one city. You will be able to choose which version of the recordings you’d like (programs with Los Angeles Faculty or San Francisco faculty).


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What You Will Learn

Expert Witnesses: The Dos, Don’ts, and Maybe’s

  • How to select persuasive Expert Witnesses (and avoid the time bombs)
  • Preparing successful Expert Witness reports and exhibits
  • Ethically and effectively prepping the Expert Witness for deposition
  • Moving to disqualify your adversary’s expert
  • How to prep to depose the other side’s Expert Witnesses
  • How to recover when your Expert Witness fumbles or worse
  • Direct examination of your own Expert Witness
  • Preparing, outlining, and carrying out the cross

Federal Court Boot Camp (15th Annual): The Nuts and Bolts

Intro to program and Federal Court

  • We’re not in Kansas Anymore: Overview of Practical Differences Between State Court and Federal Court Practice
  • Material Differences Among California’s Federal Districts
  • Highlights from the Local Rules and Local Practice
  • Rule 1 mention

Complaint and Answer Rules, Differences, Advice and Strategies 

  • Plausibility Standard: Rule 8’s Short and Plain Statement
  • Forms of Complaints and Answers/Defenses
  • Defenses vs. Affirmative Defenses
  • Practice Pointers and Pitfalls

Case Scheduling and the Case Management Conference in Federal Court

  • Rule 16.1
  • Case Management Reports

Rule 12 and Other Motions

  • Top ten tips for drafting Rule 12(b)(6) motions, responses, and replies.
  • How to enhance the effectiveness of memoranda addressing motions to dismiss.
  • How to address procedural issues that frequently arise when briefing motions to dismiss.
  • Additional Rule 12 motions
  • Ex Parte Motions
  • TRO or preliminary injunctions

Discovery & eDiscovery

  • CM/ECF brief overview/advice
  • Interrogatories, request to produce – differences between state and federal
  • 2015 Amendments to the Rules of Civil Procedure
    • Scope of discovery / proportionality
    • Requests for production and responses
    • Failure to preserve / sanctions
    • How courts have interpreted them
    • E-discovery
      • Overview and considerations
      • Sources and preservation
      • Authentication
      • Federal Rule of Evidence 502

Depo Strategies

    • Federal Rules related to Depos
    • Federal v. State differences
    • Subpoenas & affidavits
    • Deadlines and rules
    • Strategy and Deciding whom to depose
    • Taking good depositions
    • Making effective use of depositions at trial or for settlement

Drafting and Replying to Motions for Summary Judgment

Oral Argument Tips

Heading to Trial

  • Trial Briefs
    • Pretrial Statement
    • Pretrial Conference and Order

Pre-Trial Matters

  • Your Jury:
    • What is unique about Jury Selection in Federal Court?
    • Questionnaire and Voir Dire Tips
    • Jury Instructions in Federal Court
    • Jury Verdict Forms in Federal Court
  • Motions in Limine

Trial Presentation

    • Introduction of Exhibits
    • Evidentiary Objections
    • Direct and Cross-Examinations
    • Purpose, audience and format requirements
    • Basic direct examination skills
    • Basic cross examination skills
    • Preserving the Record for Appeal

Post-Trial Motions & Judgments


Jury Selection: What Happens When …?

Overview of Jury Selection

  • Goal(s) of jury selection
  • Is it jury selection or jury de-selection
  • Socio-psychological aspects

The Law of Jury Selection: focus on ethics

  • Challenging jurors for cause: The Three-Legged Stool of Bias
  • The danger of demographics in jury selection
  • Batson/Wheeler motions in jury selection

Mechanics of Jury Selection

  • Understanding your venire
  • The mini-opening statement
  • The basic mechanics of jury selection
  • Use and abuse of questionnaires
  • Rating and tracking methods (including iPad apps?)
  • Exercising challenges
  • Strike strategy
  • Dealing with time limits

Finding Out About Jurors: Voir Dire and Background Checks

  • Ethical considerations of investigating jurors in the era of social media
  • Sources of information about jurors
  • Monitoring jurors social media
  • Questions from the bench vs. questions from lawyers

Demonstration and Analysis of Jury Selection

  • Demonstration based on a hypothetical
  • Analysis of how the issues covered earlier in the day play out in real-life voir dire

Depos: How to Master the Deposition

Overview and Strategy

  • Depositions not a “one size fits all” process – trial deposition vs. discovery deposition
  • Understanding your goals and keeping your deposition goal-driven
  • Is this depo really necessary?  Determining whether the depo is worth the time and money and what you plan to get from it for your case/trial
  • Who should attend and why
  • Thoughts on preparing specific questions and outline of themes
  • Preparing for “unexpected” answers/objections or other difficulties
  • Other tips and tricks that may give you an edge
  • Using the depo at your hearing or trial – strategies and techniques

Witness Preparation

  • How to best prepare your witness:
    • Tips and strategies
    • Difficulties to avoid
    • What happens when you have a witness who can’t or won’t take the time to be prepared – what are your options (can you do it remotely, do you drop the witness, do you roll the dice, etc.)
    • What happens when you have a witness that won’t listen to you when you are preparing them
    • What do you do if you realize during witness prep that the witness is going to be a disaster (too angry, bad presence, lies, too weak, rambles too much, a danger to your case, anything along these lines) – including when you are working under a more senior partner or when you are the decision maker
    • Anything else you can think of that you’ve had to deal with not covered above
  • The percipient witness vs. a PMK
  • Ethical considerations

Expert Witness Depositions

  • Effective opposition research options on expert witnesses
  • Strategies to qualify and/or attack expert witnesses
  • Attacking the expert with his/her own words from prior deposition, treatises, expert reports, etc.
  • Using Motions in Limine to exclude expert or testimony
  • Preparing Your Expert for Deposition

Handling Documents & Exhibits – Making the Record; Get the Authentication You Need

Impeaching the Witness – Practical Advice and Strategies
Deposition Objections

  • How do I do it?
  • Why do I do it? / Depo objection strategies
  • What to avoid
  • Biggest risks in objecting and not objecting
  • Specific objections and real-world examples

Mock Demonstration and Discussion about Demonstration focusing on objections and impeachment

Handling the Difficult Witness and/or Opposing Counsel 

Concrete tips and advice, such as:

  • The angry opposing counsel – what do you do?
  • When opposing counsel yells – how to handle
  • Opposing counsel that objects to everything, how do you handle?
  • The witness keeps obfuscating or saying, “I don’t remember,” to everything, now what?
  • You know the witness is lying – is there anything you can do?
  • How to keep the depo from getting out of control
  • How to avoid needing to call the judge
  • The times when it is worth bothering the judge in the middle of your depo

Mock Demonstration and Discussion about Demonstration focusing on difficult witnesses/counsel

Audience Participation – Audience asks Mock Depo Questions to Attorneys on Fact Pattern Given


Superior Court Boot Camp (14th Annual): The Nuts and Bolts

The Early Stuff: Case Themes and Strategies, Advice on submitting Complaints & Answers; Demurrers and Motions to strike, CMCs

  • Case Strategies/Themes
  • Complaints and Answers Discussion:
    • Strategies
    • Common mistakes
  • Demurrers/Motions to Strike
  • Demurrers v. Answers
  • Case Management Conference / Scheduling Your Case

Discovery in State Court

  • Discovery
    • Rules, Cases, Timelines
    • Motions that occur during Discovery, including motions for sanctions
    • Overlooked Deadlines
    • Procedural Issues that are often missed/common mistakes
    • Strategies and choices
      • For Settlements
      • For Trial
    • RFPs
  • E-Discovery
    • Rules and timelines
    • Strategies
    • Cost Saving Measures
    • Mistakes not to make
    • Important state cases
  • Motions to Compel

Depositions in State Court – Rules and Advice

  • Rules Strategies & Timelines
  • Differences between Federal and State court depos
  • Deciding whom to depose
  • Taking good depositions – Mistakes not to make
  • Making effective use of depositions at trial

Motions for Summary Judgment and Summary Adjudication

  • Timelines and writing advice
  • Responses and Replies – Organization and Effectiveness
  • What is effective and what is not
  • What judges look for
  • Common mistakes not to make

Additional Motions

  • Ex parte applications
  • Continuances
  • Reconsideration
  • Motions for Sanctions
  • Motions to Exclude Witnesses from Courtroom
  • 998 offers
  • Substitution of Judges

Oral Argument

Heading to Trial

  • Final Status Conference
  • Trial Outline
  • Motions to Exclude Witnesses from Courtroom
  • Motions in Limine

Your Pre-Trial Tasks, Selecting and Dealing with Your Jury

  • Jury Selection in State Court – Procedure, Strategies and Questionnaires
  • Jury Instructions, Jury Verdict Forms
    • What to do, mistakes not to make
    • Evidence at trial
      • How to get evidence admitted / submitting exhibits at trial
      • Strategic Use of

Your Trial

  • Opening Statements
    • Strategies and Advice
  • Direct and Cross-Examinations of Lay Witnesses
  • Direct and Cross-Examination of Expert witnesses
  • Evidentiary Objections
  • Closing Arguments
    • Strategies and Advice

4:45 – 5:30
Preserving the Record for Appeal, Post-Trial Motions and Judgments

  • Preserving the Record for Appeal
  • Post-Trial Motions
    • Motion for a JNOV
    • Motion for a New Trial
    • Attorneys’ Fees
    • Determining “Prevailing Party” under CCP Sec. 998, 1032 & 1033
    • Filing Notice of Appeal
  • Judgments
    • Financial awards
    • Injunctive relief
    • Requirements for entry in jury trials per CCP664
    • How to enforce


Expert Witnesses: The Dos, Don’ts, and Maybe’s

“Terrific – very helpful and knowledgeable.” – Paul Carreras, Esq.

“Practical approach and good examples. Helps to learn from a judge.” – James Lemieux, Esq.

“Very good tips and helpful examples from real life.”

“Good grasp of federal and state litigation rules.”

“Very helpful comments and insight into judicial mindset.”

“Very clear presentation; good explanation of reasons behind deposition strategies.”

“The core principals were applicable and well presented.”

“The speakers were excellent and compelling.”

“Very helpful to trial work and to testifying as an expert witness.” – Richard B. Macgurn, Esq.

“I have very little experience with expert witnesses. Program gave a good background on the topic.” – Rachel Sanders, Esq.

“One of the best seminars I have attended.”

“Engaging and informative – well done.” – Marc Srodulski, Esq.

“Excellent panel!” – Michael Hannigan, Esq.

“Very well prepared and very knowledgable.” – Shawn A. Warner, Esq.

“Very clear & focused presentation.”

“Excellent discussion of federal & state law rules.”

“One of few times a seminar has lived up to [its] sales pitch.”

“Very prepared. Great suggestions. Excellent materials.” – David Olmstead, Esq.

“This was a good review/survey of how to handle expert witnesses.”

“Federal practice perspective was most relevant to my practice.”

“Very thorough and insightful.”

“Straight forward. Good use of handouts.”

“Clear, concise and effective.”

“Well done.”

“Appreciated the thorough written materials. Very helpful.”


Federal Court Boot Camp (15th Annual): The Nuts and Bolts

“Great program! Very informative and interesting. Looking forward to future seminars.” – Iveta Ovsepyan, Esq.

“I didn’t know much about federal civil practice, so it was nice to get a start to finish overview. It wasn’t overwhelming. It was a good procedural overview with practical tips.” – Kree D. Filer, Esq.

“Great to hear the perspective of a clerk. I found the voire dire tips to be very helpful. Loved the 8 components for opening statement and the points on evidence and cross-examination.” – Michelle Rahban, Esq.

“This is a great survey course regarding differences between state and federal court. Judge Olguin’s comments always included practical advice that is extremely helpful and adds to the topics substantially. He is great. Judge Segal had the best, most substantive interjections. I’d go to any discussions or lectures led by her. Excellent!” – Grace Lau, Esq.

“Good intro to topic.” – Peter Fidopiastis, Esq.

“Great mix of judges, clerks, and practitioners.”

“Excellent training!”

Jury Selection: What Happens When …?

Great seminar – particularly compared to something I listened to on CD from another MCLE provider.” – Ardith Juan, Esq.

I was very satisfied. I picked up a lot of very useful insights from a panel obviously experienced and talented attorneys.” – Luke Ryan, Esq.

Very professional and informative presentation. Panelists worked so well together – very impressive.” – Ardith Juan, Esq.

Excellent program full of practical examples; loved the demonstrations at the end.” – Kimberly Smith, Esq.

Very informative, a lot of great insight from trainers.”

Good seminar, better than most.” – Bill Slaughter, Esq.

”Excellent program.” – Paul Blatz, Esq.

The live demonstration was incredibly helpful in illustrating the lessons discussed during this seminar.” – Fritzgerald A. Javellana, Esq.

As a defense attorney, I am regularly staring down the barrel of jury selection with little or no time to prepare. This program helped point out the major points i should focus on during jury selection.” – Anthony Burchell, Esq.

Very helpful and well organized. It was good to hear both sides of various issues.”

Very good information; learned a lot.”

I liked it, very useful.”

Excellent presentation and information.”

The area/topic of jury selection is very unique and interesting.”

Very good seminar overall.”

This was very helpful.”

Depos: How to Master the Deposition

“Great time – Ryan McNamara and Paul Traina were fantastic.” – Zac Cohen, Esq.

“Wonderful speakers.” – Jennifer Misetch, Esq.

“All speakers were awesome. I was particularly impressed with Ryan McNamara. Thank you very much!” – ChaHee Lee Olson, Esq.

“I was extremely satisfied! I felt like all my misconceptions and unanswered deposition questions were sufficiently covered. Before today I felt ‘half-baked’ regarding depositions, but after the seminar, I feel confident and a lot more knowledgeable. Overall, a great learning experience.” – Aisha Oyarekhua, Esq.

“Insightful and practical preparation tips.” – Brennan Mitch, Esq.

“Very informative session. The tips and strategies presented today made me rethink what I need to do in discovery.” – Lorelei English, Esq.

“It helped give me more insight on how to prepare for future depos. I liked the deposition acting at the end!” – Cleve Collado, Esq.

“Very informative, especially for a new attorney with minimal depo experience.” – Nick Colla, Esq.

“Very clear, succinct.” – Beth Hodess, Esq.

“Fully satisfied.” – Jay Wither, Esq.

“The LiveNote and mock depo demonstration was very helpful/practical.” – Wendy Wang, Esq.

“Overall, outstanding panel for depositions – all speakers have great war stories and depo strategies for new attorneys and seasoned attorneys alike.” – Darlene Hernandez, Esq.

“Great and useful topic.”

“Excellent and thoughtful.”

“It was very helpful.”

“Great! Best CLE ever!”

“Good summary of existing law as to objections – very useful for practice.”

“Great practical tips supported by real world examples bolstered by video and transcript excerpts!”

“Helpful, practical insight regarding plaintiff depos. Good tips on current ethical considerations. The presentation on objections was most applicable to my situation and will definitely help in my practice. Good variety of presenters who work well together.”


“A good framework for taking and defending depositions.”

“Provided practical tips to utilize in deposition and concrete examples.”

“Good balance between plaintiff and defense comments, liked the examples.”

“Everyone was excellent, knowledgeable, approachable, great. Best speakers I have had.”

“My objective of learning practical advice and tips about defending and taking deposition was fully satisfied. Good variety of presenters who work well together; after attending, I am slightly less terrified to take the next deposition.”

“Last Thursday I took and defended my first deposition. Although I have not yet seen the transcript, I believe the deposition was a great success. The reporter was shocked to hear it was my first deposition. I write this not to toot my own horn, so to speak, but rather to tell you how valuable it was to hear your presentation and insights during the all-day deposition training last fall. Long story short, thank you for helping make my first deposition smooth and successful.”

“Fantastic panelists! Extremely engaging and helpful! Excellent program! 5-star presenters!! Practical advice and helpful tips.”

“I received a lot of good information and case law regarding depositions.”

Superior Court Boot Camp (14th Annual): The Nuts and Bolts

“The high-level overview is very helpful as a new attorney in trial. The personal stories were also very insightful. Great stories. I liked to hear about the judge’s time on the bench and what he didn’t like.” – Bridget Cho, Esq.

“All speakers were very good. Will recommend.” – Tom Skinner, Esq.

“Provided information that was useful and practical in assisting me with being a competent litigator and performing my job duties. Great speakers. Judge Kleinberg was very good at providing hypotheticals that relate to real-life experience. Speakers provided useful information as to when and whether to request a trial by jury and the use of pre-emptory challenges. Judge Ulmer was good at providing trial strategy as well as tips on jury selection and what to look out for (i.e., whether the jury will award damages).” – Christina Brogden, Esq.

“I really appreciated all of the judge’s additional comments. Lots of great information. Excellent practical advice and information.” – Mary Grace Guzmán, Esq.

“I received a better understanding of later parts of the life of a case. This was helpful to put things in perspective. I have a better understanding of how to run my cases and had a few new ideas during this training.” – Adam Truong, Esq.

“Really enjoyed Judge Krasnow’s commentary!” – Aurora Thorne, Esq.

“Litigation process was comprehensively covered.” – Jackson Morgus, Esq.

“Great general overview with tips.” – Flor Tataje, Esq.

“Really helpful tips with the trial prep timeline. Great handouts that I will use all the time. Loved hearing the judge’s war stories. Very helpful tips for dos and don’ts.”

“Great content and tips. Great speakers! Great to hear a judge’s POV. Excellent substantive additions. Complex topics presented very well (trial session).”

“The interactive nature of the panel was helpful (i.e., this was NOT a set of canned presentations by individuals while the other panelists just sat there). Each of the judge-panelists were quite good.”

“Really helpful/practical information. Good lecture on oral argument and heading to trial. Very good presentation. Very knowledgeable speakers.”

“I appreciated the valuable details shared in each step of the trial process. The speakers’ personal experiences and anecdotes were very valuable.”

“The mix of speakers provided for varied perspectives that were illuminating. I especially benefitted from the interactions among the panelists. It brought out more details, made it practical, and maintained the audience’s attention. Erickson and Burbidge were very engaging.”

“Program was very informative. I liked the progress of moving an entire case through trial/appellate review. Good practical tips. Exemplars are very helpful. Good tips on preparing for trial. I liked the timeline as a guide of what to think about for trial. Good insights regarding jury selection; good practice pointers regarding when to use jury questionnaires. I liked hearing the judge’s perspective regarding what he reads first in MSJs. Good to learn about his dos and don’ts.  I liked hearing about the pros and cons of juror questions and learning about how to prepare witnesses and how to get a witness to engage the jury.”

“I’ve done transactional work my whole legal career, so this was great. I’ve started taking on more litigation work. Very good information. Effective structure and presentation.”

“Good overview of the basics.”

“The checklist for trial prep was very helpful.”



Please click on the links below to view the faculty for each program.

Expert Witnesses: The Dos, Don’ts, and Maybe’s (2013)
Federal Court Boot Camp (2019)
Jury Selection: What Happens When …? (2015)
Mastering the Deposition (2018)
Superior Court Boot Camp (2019)

A few of the above programs were recorded in more than one city. You will be able to choose which version of the recordings you’d like (programs with Los Angeles Faculty or San Francisco faculty).


Save $826 when you order the bundle!

(If you were to purchase each program separately, the cost would be $2125)


Audio Recording & Materials Package – CD or Download: $1299

For CDs, please add $8.50 shipping and, in CA, sales tax.

CLE Credit

CA General:  This bundle is approved for 33.5 units of general CLE in California.

This program is approved for CLE in the states listed above.  Upon request, Pincus Pro Ed will provide any information an attorney needs to support their application for CLE approval in other states other than what is listed above.


Terms and Policies

Recording policy: No audio or video recording of any program is permitted.

Seminar Cancellations: Should you be unable to attend for any reason, please inform us in writing no later than 14 days prior to the event and a credit voucher will be issued. If you prefer, a refund, less a $50 non-refundable deposit, will be issued. No refunds or credits will be given for cancellations received within 14 days of an event. However, if you notify us within 14 days of an event, and wish to convert your in-person attendance registration to an Audio CD package (with handout), we can do so. A small additional shipping charge, and sales tax in CA, will be incurred. No shipping charge is incurred for downloads. We will also issue a voucher for the amount paid if you notify us within 14 days and prefer not to have the audio recording.

Substitutions may be made at any time.

Webinars, Tele-seminars and Webcast Cancellations: Once log-in codes and passwords are issued for a webinar, tele-seminars or webcasts, a refund is not possible. If for any reason you cannot attend the event after you have received the codes, we will automatically convert your registration to an instant streaming/instant download or CD format and provide you with the information you need to access the recording after the program concludes and the recording is available.  Conversions to CD require a $8.50 shipping fee, and in CA, 9% sales tax.

Downloads/CDs/DVDs – Refund policy:

Downloads are non-returnable/non-refundable once purchased and received. Tapes, CDs and DVDs are returnable for a full refund or replacement if defective, within 90 days of purchase.

Reminder: The room temperature at hotels and other seminar locations are notoriously hard to control. Please bring a sweater or jacket in case it gets cold and/or layer as if you are going to the movies so you are comfortable.

$2,125.00 $1,299.00 each