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Rule 30(b)(6) is designed to prevent organizations from ?sandbagging? opponents at trial by making a ?half-hearted inquiry? into matters before depositions ?but a thorough and vigorous one before the trial.? See, e.g., Bd.
30(b)(6) as requiring organizations to designate a knowledgeable witness on the specific topic noticed. This requirement is especially important when the party issuing the notice cannot identify an appropriate witness within the organization due to the specialized nature of the knowledge.
JF: A deposition is an opportunity for parties in a civil lawsuit to obtain testimony from a witness under oath prior to trial. It's part of the discovery process by which parties gather facts and information so they can be better prepared at trial to present their claims and defenses.
Under Rule 30(b)(6), the deponent ?must make a conscientious good-faith endeavor to designate the persons having knowledge of the matters sought by [the party noticing the deposition] and to prepare those persons in order that they can answer fully, completely, unevasively, the questions posed?as to the relevant ...
5 Steps for Responding to a Deposition Notice Analyze the documents that were served. ... Notify the party deponent. ... Decide whether to contact a nonparty witness. ... Object to defects in the deposition notice. ... Object to the production demand.
The Uniform Interstate Deposition & Discovery Act, VA Code §8.01-412.8 through §8.01-412.15, provides that a party may submit a subpoena from a court of record from another state to the Clerk of the Circuit Court serving the jurisdiction in which discovery is sought.
A subpoena shall advise a non-party organization of its duty to make such a designation. The persons so designated shall testify as to matters known or reasonably available to the organization. This subdivision (b)(6) does not preclude taking a deposition by any other procedure authorized in these rules.