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Rule 30(a)(2)(A)(i) limits the number of depositions to 10 ?by the plaintiffs, or by the defendants, or by the third-party defendants.? In other words, the limit is 10 depositions per each side. The parties can stipulate to exceed this limitation or a party can seek leave of court.
Summary. Rule 30(b)(6) allows for depositions of corporate representatives and their testimony is binding on the company. Counsel for noticed companies should review 30(b)(6) notices carefully and object if the notice seeks out-of-bounds testimony.
We all know that Federal Rule of Civil Procedure 30(b)(6) permits a party to notice or subpoena the deposition of ?a public or private corporation, a partnership, an association, a governmental agency or other entity and must describe with reasonable particularity the matters for examination.? (emphasis added). Making Sure the Correct 30(b)(6) Witness Is Produced in Response ... americanbar.org ? groups ? young-advocates americanbar.org ? groups ? young-advocates
The ability to demand an entity produce a witness as the entity's person most knowledgeable (PMK) on a matter is a civil procedure gift. This might be driver training, worker safety, needlework? There's no limit on the number of PMK depositions, nor on the categories one can ask.
These cases stand for the proposition that if a party notices and takes a 30(b)(6) deposition at an early stage of a case, that party will not automatically be able to notice and take another 30(b)(6) deposition on different topics later in the case. Preparing and Responding to the Rule 30(b)(6) Notice Markowitz Herbold ? Preparing-and-Res... Markowitz Herbold ? Preparing-and-Res...
Unless otherwise stipulated or ordered by the court, a deposition is limited to 1 day of 7 hours. The court must allow additional time consistent with Rule 26(b)(1) and (2) if needed to fairly examine the deponent or if the deponent, another person, or any other circumstance impedes or delays the examination.