Common Questions on 30(b)(6) Depositions

An Interview and Q&A with Mark Kosieradzki

Mark R. Kosieradzki

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Nationally renowned 30(b)(6) expert, Mark Kosieradzki, offers valuable advice on how to use your depositions to beat the defense at their own game. In this deposition CLE, Kosieradzki gives listeners a lesson on best practices for document depositions and then tackles other topics that frequently come up in FRCP 30(b)(6) depositions, such as:

  • Why 30(b)(6) depositions are useful in both state and federal court cases
  • Why rule 30(b)(6) isn't restricted to just corporate depositions
  • How to get the right person to show up at your deposition who actually has the answers to your questions
  • Why you should ask how the documents are disseminated
  • How to narrow down the sheer volume of documents that you will need from the defendant
  • How to prove that the objections for your requests for documents are improper
  • How to prepare the deponent for the 30(b)(6) deposition
  • The status of efforts to weaken 3(b)(6) on the federal level
  • The best time to take FRCP 30(b)(6) depositions
  • How to get a straight answer out of a witness
  • How to ask effective questions
  • How to deal with last-minute written objections to the topics listed in the notice other than with a motion to compel or getting a judge involved. 
  • Speaking objections versus last-minute objections
  • How to go about listing and carefully phrasing the matters that you wish to be discussed
  • Why the quality of the matters of inquiry are so important
  • What to keep in mind regarding the seven-hour limit on 30(b)(6) depositions
  • A discussion of case law to support the right to inquire about causation
  • The pros, cons, and advice on declaring the testimony of the designee as binding
  • How 30(b)(6) may be used to facilitate discovery of the complete audit trail in cases involving electronic health records
  • Issues to address when a defendant wants to bring several people to testify at a 30(b)(6) deposition
  • Dealing with representatives who are thousands of miles away from the jurisdiction the case is in
  • Effective ways to question the deponent about their expert witness reports
  • How to handle requests for documents that are kept in a general database that is routinely purged
  • The best use of 30(b)(6) in a malpractice case against a resident at a defendant hospital

In the interview and Q&A to this deposition CLE, Koeieradzki answers your questions and arms you with the tools you need to successfully take on your opponent at your next 30(b)(6) deposition. 


*This interview was originally offered to customers as part of our Trial Guides LIVE Fireside Chat series. The content has been remastered and edited for brevity and clarity.

Audio Digital Download: 100 minutes; 1st edition (2019)
Publisher: Trial Guides, LLC
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