A recent discovery ruling from an Ohio federal magistrate judge offers a helpful primer on how corporate representatives should prepare for depositions. The ruling, In re FirstEnergy Corp. Securities Litig., No. 2:20-cv-3785...more
A good 30(b)(6) can have a dramatic effect on a variety of litigation issues, from privilege issues to dispositive ones. Finding the “right” witness (or group of witnesses) who have the knowledge and skillset to be a good...more
Previously, I wrote about a proposed amendment to Federal Rule of Civil Procedure 30(b)(6) that would create a meet and confer requirement among counsel concerning the topics for examining a corporate representative in a...more
Failing to adequately prepare a corporate witness for his or her 30(b)(6) deposition can have serious consequences. In fact, courts treat an unprepared 30(b)(6) witness as a witness who simply never bothered to show up for...more
When we prepare 30(b)(6) corporate representatives and executives for their depositions, they are often fearful that the questioning attorney will try to trick them into admitting something that is not entirely accurate. They...more