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

Xavier O. Carter
Attorney
Watkins Lourie Roll & Chance
Mr. Carter's practice focuses on medical malpractice, nursing home abuse and neglect, catastrophic trucking and... | Read More
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.
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Lindsay A. Forlines
Partner
Forlines Law
Ms. Forlines' background stems from multiple years of experience representing defendants in medical negligence and... | Read More
Ms. Forlines' background stems from multiple years of experience representing defendants in medical negligence and wrongful death cases. Before joining the Plaintiff’s Bar as of January 1, 2020, she spent multiple years representing defendants in medical negligence and wrongful death cases. In that role, Ms. Forlines represented countless corporate and individual defendants, giving her intimate knowledge into the way these cases are defended, how these cases are handled by the risk management teams, and, importantly, how they are evaluated by the insurance carriers. As a plaintiff’s lawyer, she specializes in taking complex medical malpractice cases of catastrophic damages, often wrongful death. Ms. Forlines is proud to have two trials as a plaintiff’s lawyer under her belt, one as assistant counsel to Lance Lourie, Stephen Chance and Xavier Carter, and one as lead trial counsel alongside Mr. Lourie and Mr. Carter. Both of these trials involved wrongful death in the long-term care setting, and both resulted in plaintiff’s verdicts and an award of attorney’s fees and punitive damages.
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Mark R. Kosieradzki
Founder
Kosieradzki Smith Law Firm
Mr. Kosieradzki represents those who have been seriously injured or their relatives in cases involving catastrophic... | Read More
Mr. Kosieradzki represents those who have been seriously injured or their relatives in cases involving catastrophic injury, including nursing home abuse, sexual assault, medical malpractice, products liability, and vehicle crashes, among others. He is a past president of the Minnesota Association for Justice, the Association of Trial Lawyers of America Board of Governors for the American Association for Justice (AAJ, formerly known as the Association of Trial Lawyers of America), and is a past Chairperson of the AAJ Nursing Home Litigation Group.
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