30(b)(6) Depositions

A long time ago I had a very short post linking to a piece in the Washington State Bar News about depositions under CR 30(b)(6). Since then, it seems that every time I look at SiteMeter to see what sort of searches bring people to this blog, I find searches for 30(b)(6) or 30b6.

People seem to want to know about this. So I figured: let's gather some information. I asked law librarianship student Kelly Aldrich to see what she could find. Here's her guest post:

Federal Rule of Civil Procedure 30(b)(6) and Washington state Civil Rule 30(b)(6) permit a party to compel a corporate entity to designate an agent to testify on its behalf regarding topics outlined in a Rule 30(b)(6) deposition notice or subpoena. Rule 30(b)(6) effectively shifts the burden away from the requesting party (who no longer has to guess at who in the corporate entity may be knowledgeable about a given topic) and toward the corporate entity being deposed or subpoenaed (as the responding entity is in the better position to identify who within the organization is best suited to testify about a given topic).

30(b)(6) depositions are commonplace in litigation involving or concerning corporations. If you represent a party in litigation against a corporate entity, you will want to know how to effectively use and prepare for a 30(b)(6) deposition. If you represent a corporate entity, you will want to know how to advise your client about how to choose an appropriate person to testify on its behalf. And, you’ll want to understand how to adequately prepare the corporate deponent for the 30(b)(6) deposition. It is, after all, the corporate entity being “deposed.”

Here are some resources:

• Steven Caplow, The Art of the CR 30(b)(6) Deposition, Wash. St. B. News, Oct 2005.


• Candace A. Blydenburgh, Picking and Preparing Your Corporate Witnesses for Rule 30(b)(6) Depositions, The Practical Litigator, July 2002.


• Jonathan Sablone, Not Your Father’s Keeper Deposition, The Discovery Standard.


• Susan J. Becker, , Discovery from Current and Former Employees, ABA Publications, 2005, preview available on Google Books. (The library owns this, but unfortunately it's been checked out and is long overdue.)


• Robert A. Schwinger & Philip A. Pfeffer, Selecting And Preparing Corporate 30(b)(6) Witnesses, Metropolitan Corporate Counsel, Sept. 2003, at 1.


• Sidney I. Schenkier (U.S. Magistrate Judge for N.D. Illinois), Federal Rule of Civil Procedure 30(b)(6), GP/Solo, Sept. 2003.


• The 30(b)(6) Witness, Concurring Opinions Blog, April 18, 2006.

Thanks, Kelly!