Civil Procedure 30(b)(6) Deposition
to when the F.R.C.P. 30(b)(6) deposition
may be taken, how the deposition must
be noticed, what topics can be addressed,
and the length of the deposition. In
particular, leave of court is required to
depose a corporate representative of a
party or non-party when (1) the deponent
is incarcerated, or (2) the parties have not
stipulated to the deposition and (a) the
topics to be covered would require more
than 10 depositions, or (b) the deponent
parties have not held the initial discovery
conference required in Rule 26. Leave
of court is not required to depose a
corporate representative if the deponent
is not incarcerated and will be available
in the United States at or after the time
scheduled for the deposition.
must give reasonable written notice to
every party; must state the deposition
time, place and location; must state
Sullivan, P.A., where he practices insurance
defense as well as life, health and disability
litigation. He is admitted to the Florida Bar, U.S.
District Court, Southern, Middle and Northern
Districts of Florida and the U.S. Circuit Court of
Appeals for the Eleventh Circuit.
Sullivan, P.A., where she defends cases arising
from trucking accidents. Before joining Ogden &
Sullivan, she operated a solo practice focusing
on securities litigation.
5422 Bay Center Drive, Suite 100
Tampa, Florida 33609
bcombs@ogdensullivan.com
ogdensullivan.com
under Federal Rules of Civil Procedure
(F.R.C.P.) 30(b)(6) are often the most
critical event in corporate litigation.
There are a myriad of procedural and
substantive considerations that must
be addressed prior to a F.R.C.P. 30(b)
(6) deposition. This article will provide
procedural and substantive considerations
for outside counsel in preparing their
corporate representative witnesses for a
F.R.C.P. 30(b)(6) deposition.