Defending Rule 30(b)(6) Corporate Depositions: Responding to Deposition Notices, Selecting and Preparing Witnesses

*** The date for this program has changed from 9/14/17 to 9/26/17 ***

A live 90-minute CLE webinar with interactive Q&A

Tuesday, September 26, 2017 (in 5 days)
(Alert: Event date has changed from 9/14/2017!)
1:00pm-2:30pm EDT, 10:00am-11:30am PDT

This CLE webinar will prepare general counsel and outside counsel to effectively defend depositions of corporate representatives during the course of pending litigation. The panel will discuss how to respond to a Rule 30(b)(6) deposition notice and how to select and prepare witnesses for the deposition.


The Rule 30(b)(6) corporate deposition can be a valuable tool, a non-event, or a serious problem. Preparation for and defense of a corporate deposition directly impacts the success of a case and potentially future cases. With a high potential for all of the problem areas for the careless, counsel must know how to effectively prepare for and defend a corporate deposition.

Rule 30(b)(6) depositions present complex challenges and serious legal risks for a company. Counsel must strategically determine who should represent the corporation at the deposition, how much preparation is adequate, and how to deal with privilege issues.

Listen as our panel of experienced business litigators explains how companies, through their general counsel, can minimize risk to the company when responding to a Rule 30(b)(6) deposition notice and in selecting and preparing witnesses for the deposition.


  1. Key aspects of Rule 30(B)(6) that differentiate it from other forms of discovery
    1. This is not a “PMK” deposition
    2. Why limits may not apply here
  2. Considerations when responding to a notice of deposition
    1. Issues to consider when receiving and responding to a notice of deposition
    2. Best steps for negotiating with counsel, objecting and filing an appropriate motion
  3. Selecting and effectively preparing a corporate representative for deposition
    1. Attributes of good Rule 30(b)(6) witnesses and things to avoid
    2. Best strategies for “educating” a witness in advance of a deposition
  4. Preparing for the use of the 30(b)(6) testimony at trial
    1. Designating a lawyer as a Rule 30(b)(6) witness
  5. Properly defending the deposition
    1. Responding to questions beyond the scope of the notice
    2. Handling aggressive questions and a noncompliant witness
    3. How to properly respond to inaccurate or incomplete information
    4. When the deposition ends, the defending attorney’s job does not
  6. Problem areas to avoid and what may be at risk
    1. Common problems
    2. Court rulings and sanctions
  7. Final tips for the taking and defending attorney
    1. Serving a good notice
    2. Preparing for the deposition
    3. Following up on bad answers, including whether and when to file a motion to compel
    4. Using Rule 30(b)(6) testimony at trial


The panel will review these and other key issues:

  • How should corporate counsel respond to a Rule 30(b)(6) deposition notice that appears to be vague, overbroad or seeks privileged information?
  • What are the particular dangers of designating a lawyer, or someone else with extensive privileged information, as a 30(b)(6) witness?
  • To what extent must or should general counsel educate a witness in advance of a 30(b)(6) deposition?


Michael R. Gordon, Founder and Partner
GordonLaw, New York

Mr. Gordon focuses on complex commercial litigation. He has substantial experience trying cases in state and federal courts and handling domestic and international arbitrations. He also represents clients in proceedings outside ordinary litigation forums, including the New York State Banking Department and the U.S. Office of Comptroller of the Currency. He has experience conducting internal investigations and working with forensic accountants, investigators and other consultants and experts.

Casey D. Laffey, Partner
Reed Smith, New York

Mr. Laffey is a seasoned litigator and trial lawyer with extensive knowledge in various areas of law. His practice is devoted to a wide range of commercial and financial services litigation. Mr. Laffey has experience handling litigations in both federal and state courts, as well as in complex arbitration proceedings. He has extensive experience arguing complex trial court motions and appeals, taking and defending complex depositions, and has commenced and defended various actions seeking injunctive and declaratory relief. Mr. Laffey has also tried significant cases and arbitrations through verdict or award.

Andrew L. Morrison, Partner
Manatt Phelps & Phillips, New York

Mr. Morrison is a commercial litigator who specializes in business disputes and securities litigation. He represents clients across a wide range of industries, including real estate, financial services, investment banking and technology. Mr. Morrison has extensive experience handling partnership and shareholder disputes, fiduciary duty claims and crisis management. He has successfully defended many issuers, board members, syndicators, funds and advisors against securities fraud claims brought under both the ’33 Act and the ’34 Act in addition to litigating contests for corporate control.

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