Tackling Voluminous Deposition Notices (On-Demand)

Course Description

Perhaps you received a Rule 30(b)(6) deposition notice listing over a hundred topics and are wondering where to start when preparing your client’s designated representative. You aren’t alone. In litigation, voluminous Rule 30(b)(6) deposition notices are common and Rule 30(b)(6) doesn’t limit the number of topics that may be included. There are several ways, however, to get opposing counsel to limit the number and scope of the deposition topics. And there are also practical strategies to draft a notice that will obtain the discovery you need while minimizing the risk of motion practice. This 1-hour CLE will discuss how to tackle voluminous Rule 30(b)(6) deposition notices.

Syllabus

1. Strategies for Responding to a Voluminous Rule 30(b)(6) Deposition Notice
   • Step 1: Triage the Notice
   • Step 2: Meet and Confer
   • Step 3: File for a Protective Order
   • What Not to Do? Wait Until After the Deposition
2. Strategies for Drafting a Rule 30(b)(6) Deposition Notice
   • How to Draft Topics That Are Reasonably Particular and Specific
   • How to Keep the Number and Scope of Topics Proportional to the Needs of the Case

Instructor

Jason Balich, Esq. 

Alexandra Kim, Esq.