Rule 30b6. (A) Method (s) Stated in the Notice.

Jul 7, 2008 · Civ. DEPOSITIONS BY ORAL EXAMINATION. 6, 2018, the parties called the Court regarding a discovery dispute. December 1, 2007). Indeed, once served with a CR 30 (b) (6) deposition notice, the entity must designate a representative who must respond “to matters known or reasonably available to the organization. Buycks-Roberson v. Circle K Corp. In appropriate cases, it may also be helpful to include reference to Rule 30(b)(6) depositions in the discovery plan submitted to the court under Rule 26(f)(3) and in E. Nov 14, 2023 · An official website of the United States government. Notice Provision of Rule 30 (b)(6)©. This Checklist covers how to notice the deposition, ask effective questions, prepare for objections from opposing counsel, mark deposition exhibits, and what to do after concluding the deposition. gov/court_rules/pdf/CR/SUP_CR_30_00_00. The Court issued a briefing schedule, a. Do not designate a specific deponent. Leave of court, granted with or without notice, must be obtained only if the plaintiff seeks to 39 Rules for 30(b)(6) Depositions . Many people think Rule 30(b)(6) is only for big federal cases, major corporate litigation, complex product liability, mass tort, or commercial litigation cases. For the reasons set forth below, the Court construes Defendant’s request Nov 23, 2021 · Summary. The rule isn’t restricted to Federal litigation. General provisions Rule 1: Effect of these rules ; Rule 2: Appearances ; Rule 3: Authority to appear ; Rule 4: Postponement ; Rule 5: Jurors ; Rule 6: Jury selection ; Rule 7: Openings: Use of pleadings ; Rule 8: Objections to evidence ; Rule 8A: Notes by jurors The Rule 30(b)(6) witness must be able to testify on behalf of the organization regarding matters known or reasonably available to the organization, even if no employee in the organization with An addition in Rule 32(a)(2) provides for use of a deposition of a person designated by a corporation or other organization, which is a party, to testify on its behalf. Anytime you want to get information from any corporation, organization or the government, then this program is for you. P. Citibank Fed. Preparation of the designated witness is crucial, as they must be ready to testify about information known or May 25, 2017 · Rule 30(b)(6) in Practice Rule 30(b)(6) was put in place to simplify the process of determining the best representative for an entity, which works in a few ways. Rule 30(b)(6) allows a party to depose a corporation Mar 28, 2017 · With respect to whether a 30(b)(6) examination may exceed the scope of the 30(b)(6) notice, courts are divided. The 30 (b) (6) witness need not have any Oct 24, 2023 · Rule 30 (b) (6) allows an entity party to designate a representative who testifies on the entity’s behalf. “Rule 30(b)(6) depositions can be used to develop the deponent's legal contentions; contention interrogatories under Rule 33(a)(2) are usually more appropriate, but the choice between the two must be made on a caseby-case basis. 30 (b) (6). (1) A party may take the testimony of any person, including a party, by deposition upon oral examination without leave of court except as provided in paragraph (2). C. This template includes practical guidance, drafting notes, alternate clauses, and Notwithstanding Rule 30 (b) (1), such a request for production at the deposition under Rule 34 shall be made with 30 days' notice to every party, although the court may allow for a longer or shorter time. Jan 31, 2018 · The timing of the 30(b)(6) deposition should also be considered. Depositions upon oral questions. Noticing parties understandably seek to avoid foreclosing certain areas of inquiry through an objection that the topic sought to be covered was not Practical Law Standard Document w-020-1252. Practical Law Practice Note 9-504-9935 (Approx. Depositions by Oral Examination. The entity must designate one or more witnesses who can testify about all matters set forth in the Rule 30 (b) (6) notice. Jan 22, 2020 · Because a Rule 30(b)(6) designated witness is presented for the purpose of speaking for the corporation, and therefore “must testify to both the facts within the knowledge of the business entity and the entity’s opinions and subjective beliefs,” testimony of a Rule 30(b)(6) witness is binding on the corporation. In particular, the rule serves a unique function in allowing a specialized form of deposition. Rule 30(b)(6) provides: “A party may in the party's notice and in a subpoena name as a deponent a public or private corporation or a partnership or association or governmental agency and describe with reasonable particularity the matters on which examination is requested. earned a nickname: ‘bandying. Efectively representing an organization in the face of discovery targeting the company and its corporate repre-sentatives mandates that an attorney learn to navigate the complexities of Federal Rule of Civil Procedure 30(b)(6). After commencement of the action, any party may take the testimony of any person, including a party, either within or without the. G. A § 9-11-30(b)(6) authorizes depositions of organizations on topics designated by the party taking the deposition through representatives designated and prepared by the organization. Jun 1, 2023 · When preparing the organization’s Rule 30 (b) (6) witness for deposition, counsel should keep in mind that a Rule 30 (b) (6) witness’s testimony is not limited to facts. " Rule 30 (b) (6) states: Notice Or Subpoena Directed To An Organization. This template includes practical guidance, drafting notes, alternate clauses, and The following are some key considerations to guide your use of Rule 30 (b) (6). Feb 26, 2016 · Federal Rule of Civil Procedure 30(b)(6) allows a party to take the deposition of an organization by identifying the topics about which the party seeks information from the corporation. Oct 6, 2015 · As you know, Rule 30(b)(6) of the Federal Rules of Civil Procedure and state counterparts allow a party to depose organizations, including corporations. That is not so. That is a mistake. A party may depose a party or witness by oral questions. A set of model questions for See full list on americanbar. Regarding Rule 37 (d), the district court ruled that, although the deponents were physically present, their inability to May 2, 2024 · Rule 30(b)(6) depositions differ from ordinary depositions and impose additional obligations on both the party taking the deposition and the organization being deposed. Direct (763) 746-7800. (a)When Depositions May Be Taken; When Leave is Required. 01 (a), 37. Depositions upon oral examination. In its notice or subpoena, a party may name as the deponent a pub-lic or private corporation, a partnership, an association, a governmental agency, or other entity and must describe with rea - sonable particularity the matters for ex-amination. 338, 343 (N. Rule 30 (b) (6) allows for depositions of corporate representatives and their testimony is binding on the company. 02 (a) and 45. To do so, a party will serve a deposition notice that includes topics upon which the party wants to question the organization. The party requesting this type of deposition must describe with reasonable particularity the matters for examination. The authorized officer or court reporter before whom the deposition is to be taken shall put the witness on oath and shall personally, or by someone acting under the direction and in the presence of the authorized officer or Nonparty Rule 30(b)(6) testimony is less appropriate for proving how the parties acted in a given instance. § 6-330. Oct 23, 2023 · This is why, in 2020, Rule 30 (b) (6) was amended to require a good faith conference between parties “before or promptly after” a corporate deposition notice is served. The Rule allows a part to name the corporation as a deponent and identify the topics of inquiry for the testimony. The rule's purpose is to streamline the discovery process. 30 (b) (6) (As amended, eff. Great Am. Large organizations defend cases by hiding information. 1995). 1 Specifically, the amendment incorporates the following Rule 1-030(C) NMRA provides that examination and cross-examination of witnesses may proceed as permitted at trial under the New Mexico Rules of Evidence, "except Rules 11-103 and 11-615 NMRA. Spring 2009. RECORDS; Case Records; Caseload Reports; Court Dates; Judicial Information Defendants. In appropriate cases, it may also be helpful to include reference to Rule 30(b)(6) depositions in the discovery plan submitted to the court under Rule 26(f)(3) and in the matters This article discusses the 2020 amendment to Rule 30(b)(6), ways the rule could be improved, and how practitioners can work around the rule’s shortcomings with best practices for anticipating and resolving disputes related to Rule 30(b)(6) depositions early in the litigation. In its notice or subpoena, a party may name as the deponent a public or private corporation, a partnership, an association, a governmental agency, or other entity and must describe with reasonable particularity the matters for examination. (3) Method of Recording. v. ’” 81 The court The rule provides for a variety of sanctions for a party’s failure to comply with the obligations of Rule 30(b)(6), ranging from the imposition of costs to preclusion of testimony and even entry of default. The deposition of a corpora - tion or other business entity under 30(b)(6) This Bloomberg Law litigation Overview walks through what should be done to properly respond to a 30(b)(6) notice of deposition under the Federal Rules of Civil Procedure. For the purposes of this rule and Rules 28(a), 37(a)(1) and 45(d), a deposition taken by telephone is taken in the by Practical Law Litigation. This Standard Document has integrated notes with important explanations and drafting tips. In product liability cases, many Rule 30(b)(6) witnesses must be taught or educated about the manufac-ture, design and warning of the product because it is likely that no single company employee has Nov 25, 2020 · Rule 30 (b) (6) depositions allow litigators to obtain binding testimony from corporate parties or entities. 30(b)(6), the scope of questioning at the deposition is not defined by the notice of deposition – instead, Fed. 1991). Idaho Rules of Civil Procedure Rule 30. by Carter E. ate, by deposition upon oral examination. For the purposes of this rule and Rules 28. Under Rule 30(b)(6), parties may take the deposition of a party or nonparty organization. First, the serving party must provide advance notice of topics that are sufficiently detailed and reasonable in relation to the time for the deposition such that the Apr 30, 2018 · This article is designed to provide a general overview of the 30(b)(6) device, as well as offer insight as to the duties of counsel when proceeding under Rule 30(b)(6), and the distinctions between a 30(b)(6) deposition and a deposition of a named witness. Vegas Constr. Rule 30 (b) (6) was devised 45 years ago to solve this problem. By noticing such a deposition, the plaintiff can require the organization to take a potentially binding position on ESI issues. See Smart Code. So the deposing party must give a notice of deposition, like the one above, that sets forth the subject matter of the deposition with “reasonable particularity. 292, 293 (D. Any party may take the deposition of any other party, including depositions taken under Rule 30(b)(6), the deposition of any disclosed expert, and the depositions of the custodian of documents without agreement or leave of court. This Note further explains how to The key objective of the 2020 amendment to Rule 30(b)(6) is to “facilitate collaborative efforts to achieve the proportionality goals” expressed in Rules 1 and 26(b)(1). Nev. (7) The parties may stipulate in writing or the court may upon motion order that a deposition be taken by telephone. Rule 30 Depositions Upon Oral Examination. A Checklist to aid counsel when preparing for and taking a Rule 30 (b) (6) deposition in federal civil litigation. Co. See Overview – Rule 30(b)(6) – Responding to Notice of Deposition: Employment; Overview – Duty to Prepare Rule 30(b)(6) Designee. N PLAINTIFF’S PROPOSED RULE 30(b)(6) DEPOSITION TOPICS [ECF NO. Dec 6, 2023 · Rule 30(a) is intended to address the problem of overuse of expensive and unnecessary depositions. 01, 37. In turn, the organization must name a person or persons to testify on its behalf by designating a specific individual for Rule 30(b)(6) specifically states: Notice or Subpoena Directed to an Or-ganization. The witness may also May 3, 2017 · The court reviewed the general rules regarding Rule 30(b)(6) depositions, observing that “Rule 30(b)(6) expressly applies to a government agency and provides neither an exemption from Rule 30(b)(6) nor ‘special consideration concerning the scope of discovery, especially when [the agency] voluntarily initiates an action. g. Rule 30 (b) (6) depositions may be used with both parties and non-parties. the parties timely filed their respective motions [ECF Nos. 03, a deposition taken by such means is taken in the district and at the place where the deponent is to answer questions. ” Id. Leave of court, granted with or without notice, must be obtained only if the plaintiff seeks PLEASE TAKE NOTICE that, pursuant to Rule 30 (b)(6), and Rule 30 of the Federal Rules of Civil Procedure, we will take the depositions of the following parties for the purpose of discovery on the dates and times listed below. 2 Whether a Rule 30(b)(6) deponent must be prepared to testify about its corporation’s “subjective beliefs and opinions” is hotly debated. 36, 37]. " The reference to Rule 11-615 NMRA addresses whether other potential deponents can attend a deposition. F. , POL . DEPOSITIONS UPON ORAL EXAMI. Additionally, under the amended rule, a subpoena issued to a third party deponent must also advise that the nonparty organization must meet and confer with This template is a Rule 30(b)(6) deposition notice that may be used in trademark litigation in federal district court by an alleged infringer (defendant) seeking discovery from a corporate trademark owner (plaintiff) pursuant to Fed. ” Rule 6(b) is a rule of general application giving wide discretion to the court to enlarge these time limits or revive them after they have expired, the only exceptions stated in the original rule being a prohibition against enlarging the time specified in Rule 59(b) and (d) for making motions for or granting new trials, and a prohibition This template is a Rule 30 (b) (6) deposition notice that may be used in trademark litigation in federal district court by a trademark owner (plaintiff) seeking discovery from a corporate alleged infringer (defendant) pursuant to Fed. The depositions will take place at Esquire Deposition Services,xxxxxx. R. It contains practical guidance, drafting notes, and alternate clauses. Feb 1, 2020 · Courts have allowed companies to designate outside consultants as 30 (b) (6) deposition witnesses. Under FRCP 30 (b) (6) and ORCP 39 (c) (6) (collectively “Rule 30 (b) (6)”), a party to a lawsuit has the right to issue a notice for the deposition of a “public or private corporation, a partnership, an association, a governmental agency or other entity. pdf. Rule 30 - Depositions Upon Oral Examination. (1) Without Leave. The service of all questions, including cross, redirect, and recross, is to be made on all parties. The 30 (b) (6) deposition is a vehicle to reverse their obstruction and find out the information they don’t want you to know. Under Rule 30(b)(6), the deponent “must make a conscientious good-faith endeavor to designate the persons having knowledge of the matters sought by [the party noticing the deposition] and to prepare those persons in order that they can answer fully, completely, unevasively, the questions posed…as to the relevant subject matters. ” The court then listed the factors that “may overcome” the general rule: • The location of counsel; Oct 26, 2016 · Table of Contents for the law library, Massachusetts Superior Court Rules. Strang and Arun J. Rule 30(b)(6) governs corporate depositions and requires the corporate entity to designate deponents to testify on behalf of the corporation as to the notice topics. Possible objections include the number of depositions, unreasonable location, lack of Dec 16, 2020 · LE 30. The deponent's attendance may be compelled by subpoena under Rule 45. 14 pages) How to Prepare for and Successfully Defend a Rule 30 (b) (6) Deposition. The rule gives the corporation being deposed more control by allowing The court began its analysis by citing the “general” rule that a Rule 30(b)(6) deposition is held at the corporation’s principal place of business “absent an agreement of the parties or justice requiring otherwise. The party who notices the deposition must state in the notice the method (s (1) Examination and cross-examination of witnesses may proceed as permitted at the trial under the rules of evidence. TION (a) When Depositions May Be Taken. The attendance of witnesses may be compelled by Subsection FRCP 30 (b) (6) specifically applies to a notice or subpoena directed to an organization for deposition. Civ. The notice must “describe with reasonable particularity the matters for Similar to FRCP 30 (b) (1) depositions, objections to form of a question and/or other conduct, when applicable, during a FRCP 30 (b) (6) deposition are necessary to preserve the objection in later proceedings. This template includes suggested topics for a deposition in a discrimination / wrongful termination case, as well as a request for the deponent to produce documents responsive to the requests set forth in Exhibit A. All Rule 30 (b) (6) requires is a notice directed to the entity that "describe [s] with reasonable Nov 5, 2013 · Federal Rule of Civil Procedure 30 (b) states: (6) Notice or Subpoena Directed to an Organization. ”. 30(b)(6). , Inc. Depositions and Discovery. In some cases, more than one witness will be asked to testify on behalf of the organization, depending on the number and breadth of the topics noticed. (a) When Depositions May Be Taken. When the need for a Rule 30(b)(6) deposition is known early in the case, the Rule 26(f) conference may provide an occasion for beginning discussion of these topics. This Practice Note explains the key issues to consider when selecting and preparing a corporate representative to testify under Federal Rule of Civil Procedure (FRCP) 30 (b) (6). Form. Ariz. 487, 510 (1970). 2008) 2. Counsel for noticed companies should review 30 (b) (6) notices carefully and object if the notice seeks out-of-bounds testimony. 30 (b) (6) empowers you to take on Goliath and win. Fed. This template is a Rule 30 (b) (6) deposition notice that may be used in trademark litigation in federal district court by a trademark owner (plaintiff) seeking discovery from a corporate alleged infringer (defendant) pursuant to Fed. , 251 F. While there is risk in designating an attorney that is directly involved in the litigation as a Rule 30 (b) (6) witness—as The parameters of a Rule 30(b)(6) deposition may vary greatly from case to case, but the following categories of deposition questions and topics will serve as a good outline when preparing questions for deposition or when preparing a corporate witness for questions by opposing counsel. If an organization is a party to the suit, this includes an officer, director, or managing agent of the organization. Unlike a deposition of an individual, a Rule 30(b)(6) deposition is noticed to the company itself, and designates specific This is the essence of a Rule 30(b) (6) deposition. Rule 30(b)(6) is silent on whether the examining party can question the deponent on matters beyond the scope of the 30(b)(6) notice and what the evidentiary consequences are for this situation Mar 24, 2021 · Effective December 1, 2020, FRCP 30(b)(6) was amended to require parties to meet and confer about the topics of examination in advance of a deposition of an organization’s representative. An expert who has prepared a report disclosed under Rule 26 (a) (4) (B) may not be deposed. The reference to “circuit” in Rule 30(b)(7) is changed to “district. Qualifications and Organizational Structure. Nov 9, 2023 · This places a heavy burden on the entity to sufficiently prepare its representative (s). Savings Bank, 162 F. 230, differ, both rules apply the same three basic requirements for depositions of an organization: (1) the deposing party must describe the subjects to be covered with “reasonable particularity,” (2) the organization must designate one Rule 30 applies in the district courts in those instances when a deposition on oral examination is permitted by Rule 26(dc). In a securities fraud class action, the defendant may request the lead plaintiff’s deposition. Sanders v. That notice identifies the topics to be covered in the deposition, and the organization being deposed must designate one or more people qualified to answer questions on the identified topics. A key purpose of Rule 30(b)(6), is “[to] curb the ‘bandying ’ by which officers or managing agents of a The Rule 30(b)(6) deposition can be an effective tool to gather information about an organization's policies and procedures relative to ESI and information technology. Summary. KotthaFederal Rule 30(b)(6) is the vehicle for taking de- his dance of the ignorant witnesses became so common it positions of corporate representatives in civil cases. See Court Opinions; see e. The deposition offers defendants an Aug 23, 2017 · Rule 30(b)(6) enables a party to serve a deposition notice on the organization involved in the litigation rather than an individual. Who Can Be Noticed Under Rule 30 (b) (1) FRCP 30 (b) (1) allows a party to notice a “person” for oral questioning. This template is a Rule 30(b)(6) deposition notice that may be used in trademark litigation in federal district court by an alleged infringer (defendant) seeking discovery from a corporate trademark owner (plaintiff) pursuant to Fed. Legal topics are not completely off-limits in a Rule 30(b)(6) deposition. gorodenkoff via Getty Images We all know that Federal Rule of Civil Procedure 30(b)(6) permits a party to notice or subpoena the deposition of “a public or private corporation, a partnership, an association, a governmental agency or other entity and must describe with reasonable The Starting Point for Effective Rule 30(b)(6) Depositions. You may object Nov 1, 2011 · Rule 30. A non-party deponent's attendance may be compelled by subpoena under Rule 45. Toll-free (888) 545-7640. D. [1] If an organization, such as a corporation, receives a notice of deposition under Rule 30(b)(6), it must What Is a Proper Rule 30(B) (6) Designation? Federal Rule of Civil Procedure 30 addresses depositions by oral examina-tion. Prior to Rule 30(b)(6)’s implementation, the rules allowing the depositions of corporate representatives were patchy and marred by a Under Rule 30(b)(6), the notice must define the topics for the deposition with reasonable particularity. 534, 539 (D. At the plaintiff’s Rule 30 (b) (6) depositions, the witnesses and lawyers exhibited obstructionist behavior. At least two legal scholars are of the opinion that “[t]here is no basis in [Rule 30(b)(6)] or its legislative history for infusin g the Rule 30(b)(6) deposition with such a function. org Fed. CR 30 (b) (6). Feb 26, 2021 · Rule 30(b)(6) has long required the noticing party to describe the matters of examination “with reasonable particularity” but noticing parties are sometimes overinclusive in their descriptions. The purpose of Federal Rule 30(b)(6) is to allow a party to depose an organiza-tion through designated witnesses. The provisions of Rule 30(b)(4) do not apply in the district courts absent a stipulation in writing by the parties or court order. V. 30(b)(6) / O. (A) Method (s) Stated in the Notice. Feb 21, 2014 · One discovery method full of peril is the Rule 30(b)(6) deposition. Ill. The depositions will be taken before a person This template objections and responses to a notice of Rule 30 (b) (6) deposition is for use by counsel for a corporate, government, or other similar entity in civil litigation that may be used in a Massachusetts state court (Superior or District Court) case. FRCP 30 (b) (6) provides that a notice or subpoena may be issued to a public or private corporation, partnership, association, governmental agency, or other entity. (a)When depositions may be taken; when leave required. Pursuant to the Federal Rules, a party may subpoena and/or notice the deposition of a corporation through a special procedure commonly referred to as a "30 (b) (6) deposition. As interpreted by many courts, Rule 30(b)(6) imposes no obligation to reveal the identity of the corporate designee to testify until the 30(b)(6) deposition actually takes place. This subsection (b)(6) does not preclude taking a deposition by any other procedure authorized in these rules. R. Apr 25, 2023 · Depositions of corporations, government agencies, and other entities including pension plans are referred to as 30 (b) (6) depositions, after the Federal Rule of Civil Procedure that governs the process. (a) When Depositions May be Taken; When Leave Required. The “one bite at the apple” rule applies to Rule 30 (b) (6) depositions. As a result, courts will now require the parties to secure the “just, speedy, and inexpensive determination of every action and proceeding” and obtain only as much Although the text of FRCP 30(b)(6) and its California state counterpart, Code of Civil Procedure §2025. ’”3 Such depositions are unique in many respects and Rule Rule 30(b)(6) of the Federal Rules of Civil Procedure, which concerns the use of a deposition notice or subpoena directed to an organization, was amended in December 2020 to require that parties meet-and-confer prior to taking such depositions or, when relevant, that the party serving the subpoena and the subpoenaed third-party do so. After commencement of the action, any party may take the testimony of any person, including a party, by deposition upon oral examination. 1. This complements the new procedure for taking the deposition of a corporation or other organization provided in Rules 30(b)(6) and 31(a). First, it narrows the field of all potential responsible managers down to one, and prevents the practice of parading several officers of a corporation through depositions with all of Mar 1, 2022 · RULE 30. Objecting to form or conduct by counsel during the deposition also provides the other party with the Contact Us Today. (2) With Leave. ” - Century Sur. Depositions: Deposition Outline for a Rule 30 (b) (6) Witness (Federal) A set of model questions for counsel to use when deposing a Rule 30 (b) (6) witness in a federal civil case. A witness may not be deposed more than once in standard discovery. The deponent must be prepared to give “full For more guidance on depositions, go to Depositions & Disputes. wa. After commencement of the action, a party may, by oral questions, depose any person, including a party, except as provided in Rule 30 (a) (2). 36]On Novemb. United States v. In one case, a federal court allowed an entity to designate one of its litigation attorneys as a Rule 30 (b) (6) witness. www. The parties may stipulate in writing or the court may upon motion order that a deposition be taken by telephone or other remote electronic means. Here's how you know Superior Court Civil Rules. Rule 30(b)(6) was added to the Federal Rules of Civil Procedure in 1970 for the express purpose of streamlining the discovery of corporate knowledge. (a) When a Deposition May Be Taken. . Mar 1, 2022 · RULE 30. This checklist explains how to craft questions in anticipation of a Rule 30 (b) (6) deposition in federal court and covers topics such as creating a deposition outline, introductory questions, phrasing questions for a Rule 30 (b) (6) designee, authenticating documents at the deposition, and handling objections from opposing counsel. courts. The attendance of witnesses may be compelled by subpoena as provided in Rule 45. A party may, by oral questions, depose any person, including a party, without leave of court except as provided in Rule 30 (a) (2). The new procedure provided in Rule 30(b)(6) for taking the deposition of a corporation or other organization through persons designated by the organization is incorporated by reference. The entity's adversary has few obligations in noticing the deposition of a corporate designee. Advisory Committee Notes, 48. Often the list of topics is long and possibly confusing. [21] So what should ABC have done differently in the hypothetical? Given the lack of a personal knowledge requirement for Rule 30(b)(6) witnesses, it is important to determine how the adverse partys designee obtained her key information. Some adhere to the rule that, “when a deponent is produced pursuant to Fed. , 137 F. Tailor the topics to the Depositions Upon Oral Examination. In practice, however, it seems as if many litigants either ignore the rule or give it short shrift, blindly finger-pointing about the failure to prepare a witness to testify A common mistake for a lawyer issuing a 30 (b) (6) notice is to assume that because there is no limit on the number of topics, there is also no limit on the number of times you can notice and take the deposition of a corporation. Ins. In fact, doing so invalidates the notice. Apr 10, 2023 · A quick primer on corporate witnesses under Federal Rule of Civil Procedure 30(b)(6). el vv cm qk rx if qd qu dl cl