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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 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, November 1, 2023

Recorded event now available

or call 1-800-926-7926

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.


Depositions under Fed. R. Civ. P 30(b)(6), or its many state law equivalents, allow personal injury trial lawyers to depose a witness, whose testimony can bind the opposing entity, and who must prepare to fully address plaintiff-specified topics. Because 30(b)(6) depositions are such a powerful tool, the deponent's counsel will take full advantage of any procedural misstep by the plaintiff's attorney.

The 30(b)(6) notice specifies the categories on which the witness must be prepared to testify. By including the proper mix of broad and narrow categories, the plaintiff's trial lawyer can avoid a defense claim that a deposition question is outside the scope of the notice. Plaintiff's counsel must equip him/herself with an outline of questions and the proper follow-up inquiries which, within the dictates of Rule 30(b)(6), can lock the deponent-entity into admissions.

Counsel should anticipate objections to the scope of the notice, no matter how well-drafted. Deponent's counsel may designate multiple representatives whose testimony is limited to specific topics to set up a later witness to "clean up" earlier testimony. Discussion during the deposition about whether testimony does or does not fit within the scope of the notice, or, whether the witness was appropriately prepared, is a near certainty. Motion practice frequently follows a 30(b)(6) deposition.

Listen as our experienced panel explains legal and practical considerations for personal injury attorneys when preparing for and conducting a Rule 30(b)(6) deposition.



  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 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?


Howard, Marc
Marc Howard

Pope & Howard

Mr. Howard is a trial lawyer with over 30 years’ experience handling complex personal injury and wrongful death...  |  Read More

Moore, Leighton
Leighton Moore

The Moore Law Firm

Mr. Moore is a fourth-generation Georgia lawyer. He earned a bachelor’s degree from Georgia State University and...  |  Read More

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Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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