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Written by Stephanie M. Wurdock.

We all know what to do when a client is asked to give his or her deposition. Once the plaintiff issues the notice, you set to work preparing your client to testify about his or her involvement in the case. You lay out the ground rules: “Don’t talk about anything we’ve discussed; only testify to those things of which you have personal knowledge; and absolutely no speculating!” These are basic deposition rules. We all know them. Not so fast. If your client is a corporation and you have been issued a notice pursuant to Kentucky Civil Rule of Procedure 30.02(6) or Federal Rule of Civil Procedure 30(b)(6), the above advice is absolutely incorrect. Not only is it bad advice, but it could result in sanctions against your client.


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