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Person most knowledgeable are persons who are appointed mainly by Corporations and Government agencies to testify on their behalf. The Federal Rules of Civil Procedure recognize that a corporation may only participate in a lawsuit by relying on the testimony of its designated representatives.
An important purpose in any deposition of a person most knowledgeable (?PMK?) is to solicit testimony from the person who has the most knowledge about your specific topic, for the relevant period.
The person deposed may be a natural person, an organization such as a public or private corporation, a partnership, an association, or a governmental agency.? A party involved in litigation in California can take the deposition of any other party including adverse parties or co-parties.
The first step in protecting the prospective deponent from an improper 30(b)(6) notice is to confer with opposing counsel in an attempt to clarify or limit the objectionable topics. For this purpose, written objections may certainly serve as a starting point.
The main purpose of a corporate representative1 deposition, whether in federal or state court, is to (i) learn what the corporation knows and (ii) obtain testimony that the corporation cannot later disclaim (unless they provide a compelling explanation).