Five-Minute Guide to FRCP 30(b)(6) Depositions

Need instant expertise on designated-representative depositions? Need help fast? Grab this field guide and go. From Jim Garrity, the country’s leading deposition expert – and author of the 2019 490-page masterwork, 10,000 Depositions Later: The Premier Litigation Guide to Superior Deposition Practice, also available on Amazon - comes this excellent field guide on “designated representative” depositions. (This manual is actually an excerpt from that practice guide.) They’re often called corporate representative depositions, or simply “30(b)(6)” depositions, referencing the applicable Federal Rule of Civil Procedure. The US Supreme Court adopted the rule creating them in 1970, but there’s still tremendous confusion about what they are and how to take (or defend against) them.

Whether you’re an expert needing a refresher or are brand new to the topic – or just want a manual to have handy at depositions – you’ll find huge value.

What’s inside? The Five-Minute Guide to FRCP 30(b)(6) Depositions explains their purpose and role in discovery, and the occasions best suited for them. Most critically, Garrity explains how to assemble the perfect 30(b)(6) topic list, which will serve as the responding entity’s marching orders when it prepares its designated representative for your deposition. Garrity includes on-point case citations to address the key drafting issue: Should your topics be hyper-specific, which can lead to very long lists? Or more general, which can result in a shorter topic list, but one that may be too generic to be useful? He also reveals the preliminary questions you should always cover at the start of every 30(b)(6) deposition, and addresses the current state of the law on being able to ask questions that go beyond your listed topics.

These discussions will be useful when you’re defending a 30(b)(6) deposition as well. But beyond that, Garrity tells you how to challenge poorly-drafted topic lists, how to choose the person(s) to serve as your designated representative(s), and how to prepare them to be powerful witnesses for the organization.

Garrity, a best-selling author on depositions, trial practice, and trial tactics, has appeared as lead trial counsel in more than two thousand federal and state civil cases. He’s been up against the best litigators at hundreds of firms, from the nation’s largest to sole practitioners, and there’s literally no tactic, trick, variation or strategy he hasn’t seen (or used) hundreds of times. His high-volume, multi-state law firm is a veritable laboratory for experimenting with approaches that win – and win, and win. Don’t miss out.