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Taking a 30(b)(6) deposition involves identifying a corporate representative who can testify on behalf of a company regarding specific topics. The requesting party must provide notice, which often includes an Illinois Notice to Produce at Deposition when relevant documents are needed. Proper preparation and clear communication are essential to ensure that the deposition is informative and productive.
Hearsay. Assume facts, not in evidence. Calls for an opinion. Speaking and coaching objections. Privilege. Form. Mischaracterizes earlier testimony. Asked and answered.
Under the Act, an out-of-state litigant seeking to subpoena an individual or entity located in Illinois must simply submit a subpoena issued in a foreign state to the clerk of court in the county in which the discovery is sought.
DEPOSITION SUBPOENA In Illinois, deposition subpoenas must be served on the deponent at least seven days before the date of the deposition, if the subpoena does not also seek documents from the non-party witness (Ill.
RULE 30(B)(6) SHOULD REQUIRE AT LEAST 30 DAYS' NOTICE IN ORDER TO ENSURE PROPER PREPARATION, AND THE DEPOSITION SHOULD BE SCHEDULED AT A TIME AND DATE AGREEABLE TO BOTH PARTIES. A. Reasonable Notice Is at Least 30 Days Prior to Deposition.