When representing a corporation or other organizational entity in federal court, it is not uncommon to be presented with a Federal Rule of Civil Procedure 30(b)(6) deposition request. There are many issues to consider when presented with this type of deposition notice. What company employee will you pick as the corporate deponent? Does it make sense to have more than one employee testify on the listed topics if the notice covers different departments? Or is it a better idea to educate one company representative to speak on behalf of all topics?
While all of these points are important to consider, you notice that the deposition notice is also accompanied by a litany of document requests. One listed topic requests that the testifying party provide to noticing counsel “all documents reviewed or used by deponent in preparation of the deposition.”
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