Taking 30(b)(6) Corporate Representative Depositions in Personal Injury Cases

Dan Schiavetta
Dan Schiavetta | Russo & Gould LLP

Dan Schiavetta, of counsel to Russo & Gould LLP in New York City, has been a litigator for 30 years and is admitted in all New York and New Jersey state and federal courts and the Second and Third Circuit Courts of Appeals.

On-Demand: June 20, 2024
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2 hour CLE
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Program Summary

Deposing a corporate representative is a critical part of making out a personal injury case. Typically they are well-prepared, intelligent, and used to being deposed and being evasive or unhelpful. Rule 30(b)(6) and associated rules have undergone changes over the years and these will be discussed. Like any deposition, there is a way to question efficiently and effectively. Dan will discuss specific situations that have arisen in his 30 years of practice.

Key topics to be discussed:

  • Establishing knowledge and avoiding “apex deposition” rule
  • Developing normally ignored aspects of personal injury case
  • Finding other witnesses, records, possible spoliation issues
  • Dealing with protective orders and motions to quash, and privilege and “business judgment” objections

Closed-captioning available

Speakers

Dan-Schiavetta,-Jr._Russo-&-Gould-LLP_myLawCLEDan Schiavetta | Russo & Gould LLP

Dan Schiavetta, of counsel to Russo & Gould LLP in New York City, has been a litigator for 30 years and is admitted in all New York and New Jersey state and federal courts and the Second and Third Circuit Courts of Appeals. For 20 years he defended the Catholic Church in sexual abuse cases and other matters. He also has wide experience in insurance coverage litigation, nursing home defense, and appellate practice. He is a 1992 graduate of the University of California, Davis School of Law where he was a law review editor and moot court judge. In his previous career as a social worker he was the director of a crisis center and 24-hour hotline. He is also the author of “The Supreme Court for Short Attention Spans: 2000 Tiny Case Summaries Too Short to Bore You”, available on Amazon.

Agenda

I. Establishing knowledge and avoiding “apex deposition” rule | 2:00pm – 2:30pm

II. Developing normally ignored aspects of personal injury case | 2:30pm – 3:00pm

Break | 3:00pm – 3:10pm

III. Finding other witnesses, records, possible spoliation issues | 3:10pm – 3:40pm

IV. Dealing with protective orders and motions to quash, and privilege and “business judgment” objections | 3:40pm – 4:10pm

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