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DOS and DON’TS of a 30(b)(6) Witness Deposition, Part Five

eDiscovery Daily

Topics that seek information regarding the knowledge of third parties, such as complaint information, persons and documents identified in initial disclosures, or information dealing with the substance of a third party’s knowledge, are improper for Rule 30(b)(6) purposes. These include: Securities and Exchange Commission v. McCabe, No.