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Rule 30(b)(6) Depositions in Employment Litigation: Strategies for Deposing and Defending the Corporate Witness

Drafting and Responding to Deposition Notices; Selecting the Right Designee; Issues Unique to Employment Claims

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

This program is included with the Strafford CLE Pass. Click for more information.
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Conducted on Wednesday, February 21, 2024

Recorded event now available

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This CLE webinar will prepare employment counsel to depose or defend corporate representatives under the amended Federal Rule of Civil Procedure 30(b)(6), taking into account issues unique to employment litigation. The program will provide best practices for plaintiffs to meet the Rule 30(b)(6) "meet and confer" requirements, draft the notice, effectively question the employer's designated witness, and handle objections. The program will also discuss how defense counsel can effectively respond to the deposition notice, select and prepare the employer's designated representative, and effectively manage the scope of the deposition.


Employment litigators frequently rely on Rule 30(b)(6) depositions as a strategic tool to question corporate representatives about specific topics and bind the corporation to the testimony. The goal is to obtain admissions and pin down the employer's positions on employment issues and company policies which it may have avoided in answering written discovery requests.

Plaintiff's counsel should guard against procedural missteps when noticing the deposition and anticipate defense counsel's objections, such as the claim that deposition questions are outside the scope of notice by including in the notice the proper mix of broad and narrow categories on which the witness must be prepared to testify.

Defense counsel should strategically determine who should represent the company. When facing employment-related claims, such as discrimination claims, counsel should ensure they have the proper witness who is familiar with the company's policies to avoid inadvertently binding the company to an inaccurate, and potentially harmful, stance. Counsel should also determine how much preparation is adequate and how to deal with privilege issues.

Listen as our expert panel guides practitioners through strategies for taking and defending 30(b)(6) depositions in the scope of employment claims. The panel will address issues unique to employment and how these may affect deposition preparation and describe best practices for plaintiff and defense counsel.



  1. Rule 30(b)(6) overview
  2. Issues unique to employment claims and how they may affect deposition strategy and preparation
  3. Plaintiff concerns
    1. Advantages vs. disadvantages of Rule 30(b)(6) witness
    2. Notice of deposition
    3. Meet and confer requirement
    4. Timing/sequence considerations
    5. Selecting exhibits
    6. Defending objections
    7. When the witness is unprepared
  4. Defense concerns
    1. Evaluating and objecting to the notice
      1. Moving for protection
      2. Privilege considerations
      3. Other objections
    2. Investigation
    3. Selecting the designee
    4. Preparing the designee
    5. Defending the deposition
      1. Objections
      2. Instructions to the witness
  5. Practitioner takeaways


The panel will review these and other important issues:

  • What issues unique to employment claims may affect how counsel prepares to take or defend a Rule 30(b)(6) deposition?
  • What considerations should plaintiff's counsel keep in mind when noticing the deposition?
  • How should defense counsel strategically determine who should represent the company in the deposition?
  • What are the particular dangers of designating a lawyer, or someone else with extensive privileged information, as a 30(b)(6) witness?


Boling, Andrew
Andrew J. (Andy) Boling

Attorney, Employment Law Chair
Kelleher + Holland

Mr. Boling represents domestic and international clients doing business in the US and around the world, especially in...  |  Read More

Chambers, Anita
Anita Mazumdar Chambers

The Employment Law Group

Ms. Chambers primarily focuses on matters of discrimination and retaliation. She has extensive experience in conducting...  |  Read More

Lewis, Robert
Robert P. Lewis

Epstein Becker & Green

For more than 25 years, U.S. multinational and domestic employers needing strong legal representation have sought out...  |  Read More

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