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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.