30(b)(6) Second Edition eBook

Deposing Corporations, Organizations & the Government

Mark R. Kosieradzki

Format: eBook
Condition: New
Sale price$195.00

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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Do you want the eBook and print book? After you complete your purchase of the print book you will receive a coupon code via email to purchase the eBook for $20.

eBook: 512 pages; 2nd edition (2020); ISBN: 9781951962098
Publisher: Trial Guides, LLC


Preface to the Second Edition


Foreword to the Second Edition by John Romano

  1. Deposing Organizations
  2. Building a Record
  3. Details of Rule 30(b)(6): Deposing Organizations by Issue Designation
  4. Rule 30(b)(6) Logistics: Location, Duration, and Number of Depositions
  5. Deposing Officers, Directors, and Managing Agents: 30(b)(1) Depositions
  6. Deposing Low-Level Employees
  7. Crafting the 30(b)(6) Notice: The Requesting Party’s Duties
  8. Scope of the 30(b)(6) Notice: What Can You Ask About?
  9. Rule 30(b)(6) Foundation Depositions
  10. Electronic Discovery
  11. Process-Based Discovery: Identifying Incomplete Discovery Using 30(b)(6)
  12. Duty to Attend
  13. Duty to Prepare
  14. Scope of Inquiry
  15. Deposition Obstruction
  16. Motions to Compel and Sanctions
  17. Binding Effect
  18. Changing the Testimony
  19. 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


About the Author

What Legal Leaders Are Saying

It’s malpractice to not study this and Mark’s book is the gold standard.

— John Romano, past president of the Florida Justice Association and editor of Anatomy of a Personal Injury Lawsuit