Taking 30(b)(6) Corporate Representative Depositions in Personal Injury Cases

Preparing the Deposition Notice, Questioning the Corporate Rep, Raising and Defending Objections, and More

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

Conducted on Wednesday, February 7, 2018

Recorded event now available

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Program Materials

This CLE webinar will prepare personal injury attorneys to depose corporate representatives in accordance with Rule 30(b)(6) of the Federal Rules of Civil Procedure. 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.


Personal injury attorneys litigating against corporations in trucking accident, traumatic brain injury, nursing home injury, medical error and other cases involving serious injuries rely on the Rule 30(b)(6) deposition as a tactical tool to question corporate representatives about specific topics related to the litigation. Testimony obtained during the deposition may be used by the plaintiff for any purpose and binds the corporation.

Getting the 30(b)(6) notice right is key to a successful deposition. There are frequent disputes over the adequacy of the scope of the notice. There is also a great deal of legal wrangling over whether the corporation fulfilled its obligation to select an appropriate deponent and properly prepare the deponent for deposition.

The expectations of the deposing personal injury attorney regarding how the 30(b)(6) deposition should be conducted almost always differ significantly from those of the corporation, making it one of the most challenging aspects of personal injury litigation.

Listen as our experienced speaker explains legal and practical considerations for personal injury attorneys when preparing for and conducting a Rule 30(b)(6) deposition. The speaker will share useful insights on the strategic and effective use of corporate depositions in personal injury practice.



  1. Law of 30(B)(6) depositions
  2. Logistics: who, how many, where, when, how long
  3. What is in the notice: permissible areas of inquiry
  4. Duties of the responding party
  5. Binding effect of testimony
  6. Scope of inquiry


The speaker 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 effective when questioning the corporate representative and raising and defending objections during the deposition?
  • What are some best practices for dealing with difficult deponents?


Kosieradzki, Mark
Mark R. Kosieradzki

Kosieradzki Smith Law Firm

Mr. Kosieradzki represents those who have been seriously injured or their relatives in cases involving catastrophic...  |  Read More

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