Nationally renowned 30(b)(6) expert, Mark Kosieradzki, offers valuable advice on how to use your depositions to beat the defense at their own game. In this deposition CLE, Kosieradzki gives listeners a lesson on best practices for document depositions and then tackles other topics that frequently come up in FRCP 30(b)(6) depositions, such as:

• Why 30(b)(6) depositions are useful in both state and federal court cases
• Why rule 30(b)(6) isn't restricted to just corporate depositions
• How to get the right person to show up at your deposition who actually has the answers to your questions
• Why you should ask how the documents are disseminated
• How to narrow down the sheer volume of documents that you will need from the defendant
• How to prove that the objections for your requests for documents are improper
• How to prepare the deponent for the 30(b)(6) deposition
• The status of efforts to weaken 3(b)(6) on the federal level
• The best time to take FRCP 30(b)(6) depositions
• How to get a straight answer out of a witness
• How to ask effective questions
• How to deal with last-minute written objections to the topics listed in the notice other than with a motion to compel or getting a judge involved. 
• Speaking objections versus last-minute objections
• How to go about listing and carefully phrasing the matters that you wish to be discussed
• Why the quality of the matters of inquiry are so important
• What to keep in mind regarding the seven-hour limit on 30(b)(6) depositions
• A discussion of case law to support the right to inquire about causation
• The pros, cons, and advice on declaring the testimony of the designee as binding
• How 30(b)(6) may be used to facilitate discovery of the complete audit trail in cases involving electronic health records
• Issues to address when a defendant wants to bring several people to testify at a 30(b)(6) deposition
• Dealing with representatives who are thousands of miles away from the jurisdiction the case is in
• Effective ways to question the deponent about their expert witness reports
• How to handle requests for documents that are kept in a general database that is routinely purged
• The best use of 30(b)(6) in a malpractice case against a resident at a defendant hospital

In the interview and Q&A to this deposition CLE, Koeieradzki answers your questions and arms you with the tools you need to successfully take on your opponent at your next 30(b)(6) deposition. 

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*This interview was originally offered to customers as part of our Trial Guides LIVE Fireside Chat series. The content has been remastered and edited for brevity and clarity.