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

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, August 31, 2022

Recorded event now available

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This CLE course will prepare trial attorneys to defend the depositions of corporate representatives during litigation. The panel will discuss how to respond to a Rule 30(b)(6) deposition notice and select and prepare witnesses for the deposition. The panel will also review the "meet and confer" requirement applicable when noticing a Rule 30(b)(6) deposition.


Rule 30(b)(6) corporate deposition can be a valuable tool, a non-event, or a significant challenge. Preparation for and defense of a corporate designee's deposition directly impacts a case's success and potential future claims. With a high potential for significant consequences caused by careless mistakes, counsel must know how to 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. Indeed, failure to prepare not only risks damaging testimony but could expose the party to further deposition time as well as financial penalties.

Listen as our panel of experienced business trial attorneys explains how corporations, through counsel, can minimize risk when responding to a Rule 30(b)(6) deposition notice and in selecting, preparing, and defending witnesses for the deposition.



  1. Critical 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. Meet and confer requirement
  3. Selecting and 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. Whether or not to designate a lawyer as a Rule 30(b)(6) witness
  5. Properly defending the deposition
    1. Responding to questions beyond the scope of the "list of matters for examination"
    2. Handling aggressive questions and a noncompliant witness
    3. How to respond to inaccurate or incomplete information
    4. When the deposition ends, the defense 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 high priority 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 Rule 30(b)(6) witness?
  • To what extent must or should general counsel educate a witness in advance of a 30(b)(6) deposition?


Jennifer Hurley McGay

Lewis Johs Avallone Aviles

Ms. Hurley McGay litigates a wide range of complex matters in both state and federal trial and appellate courts,...  |  Read More

Maloney, John C.
John C. (Jay) Maloney, Jr.

Zuber Lawler

Mr. Maloney is a trial lawyer and a highly experienced complex commercial litigator. He focuses most often on product...  |  Read More

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