“With all due respect” almost never is. We invariably use the phrase as an introduction to an insult. But just this once, I mean it.
With all due respect, many judges continue to get it wrong about Rule 30(b)(6), the rule that allows a party to depose an organization through a witness designated by the organization. Not all judges get it wrong, but too many. I respect these judges, I do, and for the most part their error is harmless, but they are wrong. They can be forgiven, because their error has been repeated in legions of reported cases. But they are wrong.
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