Much has changed since the first edition of 30(b)(6): Deposing Corporations, Organizations, and the Government was published. There is a new amendment to Rule 30(b)(6) that establishes the need to “meet and confer,” and numerous states have amended their own rules or added different provisions. And just as important, defense lawyers have invented new ways to try and evade and obstruct your ability to get to the truth.
This second edition addresses the new rule change, provides updates to state laws, discusses how to defeat the latest attempts to evade disclosures of the evidence you seek with Rule 30(b)(6), offers over two hundred new citations, and has new and updated chapters and appendices—including sections have been expanded to identify the evolving jurisprudence concerning post COVID-19 pandemic logistics.
After all, a great case still needs great evidence. The best techniques in case framing, storytelling, and presentation mean nothing in the face of evasive tactics that hide the necessary information you have a right to see. In 30(b)(6): Deposing Corporations, Organizations, and the Government, Mark Kosieradzki provides the powerful answers you need to get that evidence.
Using detailed and practical examples, Kosieradzki breaks down Federal Rule of Civil Procedure 30(b)(6) and offers the techniques you need to use it to its greatest potential. This book is your key to navigating the bureaucratic maze and building a substantial record of the defense’s words and documents to hold them accountable in front of a jury. It offers advice on communicating with cagey representatives, dealing with the defense’s obstacles, and performing effective and efficient 30(b)(6) depositions in all fifty states.
For years, advocates have quibbled over the thirty-eight deceptively simple words of Rule 30(b)(6) and asked themselves, “How do I depose something that isn’t a person?” 30(b)(6): Deposing Corporations, Organizations, and the Government is the definitive tool you need to cut through the smokescreens and end the runaround once and for all.
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Preface to the Second Edition
Foreword to the Second Edition by John Romano
- Deposing Organizations
- Building a Record
- Details of Rule 30(b)(6): Deposing Organizations by Issue Designation
- Rule 30(b)(6) Logistics: Location, Duration, and Number of Depositions
- Deposing Officers, Directors, and Managing Agents: 30(b)(1) Depositions
- Deposing Low-Level Employees
- Crafting the 30(b)(6) Notice: The Requesting Party’s Duties
- Scope of the 30(b)(6) Notice: What Can You Ask About?
- Rule 30(b)(6) Foundation Depositions
- Electronic Discovery
- Process-Based Discovery: Identifying Incomplete Discovery Using 30(b)(6)
- Duty to Attend
- Duty to Prepare
- Scope of Inquiry
- Deposition Obstruction
- Motions to Compel and Sanctions
- Binding Effect
- Changing the Testimony
- Using 30(b)(6) Testimony at Trial
Appendix A: Rule 30(b)(6) in All Fifty States
Appendix B: Sample 30(b)(6) Notice
Appendix C: Foundation Deposition Notice
Appendix D: Rule 30(b)(6) Depositions for Email
Appendix E: Contention 30(b)(6) Deposition
Appendix F: Corporate Structure 30(b)(6) Deposition
Appendix G: 30(b)(6) Federal Rule Change History
IndexAbout the Author
What Legal Leaders Are Saying
— John Romano, past president of the Florida Justice Association and editor of Anatomy of a Personal Injury Lawsuit
It’s malpractice to not study this and Mark’s book is the gold standard.