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

eDiscovery Daily

DKC 06-0866 (D. 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. Securities and Exchange Commission v.