Federal Rules of Civil Procedure, Depositions, Attorney-Client Privilege

Five Tips for Preparing to Testify at a Deposition

Kerr Russell on 7/9/2025

Preparing for a deposition can be challenging whether it is a person’s first or hundredth time testifying under oath. Being questioned frequently causes anxiety. But the experience does not have to be so daunting with...more

California Federal Court Addresses Discovery About Discovery

McGuireWoods LLP on 5/15/2025

Aggressive litigation adversaries sometimes try to make a discovery sideshow into the main event. A party’s search for responsive documents occasionally triggers such an effort....more

To Be (Discoverable), or Not to Be: Notetaking During an Attorney’s Internal Investigation

Jackson Lewis P.C. on 9/2/2022

Introduction- Picture this: you are on-site at a new client’s headquarters for a weeklong hostile work environment investigation into several internal complaints made against the CEO and CFO. This is the first engagement...more

The Apex Rule and Protecting Your Client’s Management Team When Conducting Deposition Discovery

Snell & Wilmer on 6/22/2022

The Federal Rules of Civil Procedure liberally enable parties to seek relevant information in discovery that may be helpful in the preparation and trial of a case. While the liberal scope of discovery permitted by the...more

Another Court Deals with Rule 30(b)(6) Depositions

McGuireWoods LLP on 3/31/2016

Under Fed. R. Civ. P. 30(b)(6), corporations must designate a witness to testify about the corporation's knowledge. Surprisingly few courts have reconciled this requirement with the common if not universal role that lawyers...more

Court Takes a Common Sense Approach to Rule 30(b)(6) Depositions

McGuireWoods LLP on 6/25/2015

Rule 30(b)(6) of the Federal Rules of Civil Procedure allows corporations' adversaries to insist that the corporation select a spokesman to provide binding testimony about designated topics. These depositions almost...more