Taking 30(b)(6) Corporate Representative Depositions in Personal Injury Cases
Drafting a Thorough Notice, Tying Down the Witness With Key Questions, Objecting and Filing Related Motions

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Personal Injury and Med Mal
- event Date
Wednesday, December 18, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE course will prepare personal injury trial lawyers to depose corporate representatives in accordance with Rule 30(b)(6) of the Federal Rules of Civil Procedure and its state law equivalents. The webinar will discuss best practices for meeting the 30(b)(6) notice requirements, effectively questioning the corporate representative, dealing with difficult representatives, and raising and defending objections.
Faculty

Prior to founding Randels Injury Law, Ms. Randels worked at two prominent Atlanta area injury firms for the better part of a decade. Since 2020, she has been recognized as a Super Lawyers Rising Star, an honor given to only 2.5% of the lawyers in Georgia. 2024 marks her fifth year being recognized. Ms. Randels has also been recognized as one of Georgia Trend's Legal Elite, named in Best Lawyers in America -- Ones to Watch, and is a member of the National Trial Lawyers Top 40 Under 40. Since 2020, Ms. Randels has been a member of the Georgia Trial Lawyers Association's Executive Committee, serving as chair of the New Lawyers Division, the Communications Committee, and the Women's Caucus.

Mr. Carter's practice focuses on medical malpractice, nursing home abuse and neglect, catastrophic trucking and commercial vehicle accidents, products liability, white collar crime, and whistleblower or qui tam actions.
Description
Depositions under Fed. R. Civ. P 30(b)(6), or its many state law equivalents, allow personal injury trial lawyers to depose a witness, whose testimony can bind the opposing entity, and who must prepare to fully address plaintiff-specified topics. Because 30(b)(6) depositions are such a powerful tool, the deponent's counsel will take full advantage of any procedural misstep by the plaintiff's attorney.
The 30(b)(6) notice specifies the categories on which the witness must be prepared to testify. By including the proper mix of broad and narrow categories, the plaintiff's trial lawyer can avoid a defense claim that a deposition question is outside the scope of the notice. Plaintiff's counsel must equip themself with an outline of questions and the proper follow-up inquiries which, within the dictates of Rule 30(b)(6), can lock the deponent-entity into admissions.
Counsel should anticipate objections to the scope of the notice, no matter how well-drafted. Deponent's counsel may designate multiple representatives whose testimony is limited to specific topics to set up a later witness to "clean up" earlier testimony. Discussion during the deposition about whether testimony does or does not fit within the scope of the notice, or, whether the witness was appropriately prepared, is a near certainty. Motion practice frequently follows a 30(b)(6) deposition.
Listen as our experienced panel explains legal and practical considerations for personal injury attorneys when preparing for and conducting a Rule 30(b)(6) deposition.
Outline
- Law of 30(b)(6) depositions
- Logistics: who, how many, where, when, how long
- What is in the notice: permissible areas of inquiry
- Duties of the responding party
- Binding effect of testimony
- Scope of inquiry
Benefits
The panel will review these and other key issues:
- What are some best practices for crafting a deposition notice that adequately identifies the scope of the 30(b)(6) deposition?
- How should personal injury attorneys respond when the corporate defendant designates an inappropriate deponent?
- What tactics are useful when questioning the corporate representative and raising and defending objections during the deposition?
- What are some best practices for dealing with difficult deponents?
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