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39 rules for corporate depositions

May 24, 2016 by Steven M. Gursten

Magnificently extracted by Judge Jonathan Goodman, from the oft-cited decision of QBE Insurance Corporation v. Jorda Enterprises, Inc. 277 F.R.D. 676, 687 (2012)


Michigan Auto Law's Steve Gursten discusses tips for corporate depositions.

In my national webinar today on truck accident litigation and discovery of truck drivers and corporate representatives, I mentioned the QBE Insurance Corporation opinion by Judge Goodman. This opinion has become the most important decision on 30(b)(6) depositions.

Just as the Hall v. Clifton Precision opinion has become the “bible” for lawyers and judges dealing with deposition abuse by lawyers, the QBE opinion by Judge Goodman has become the go-to source for lawyers and judges around the country today in dealing with issues on the scope and breadth of 30 (b)(6) depositions. I mentioned I would post the decision and the “39 rules” at the conclusion of my presentation, and I was clearly remiss in not attaching this critical opinion to my seminar materials.

Here are the 39 rules for corporate depositions as Magistrate Johnathon Goodman has magnificently extracted on: What is often a misunderstood and abused rule of civil discovery.

From the oft-cited decision of QBE Insurance Corporation v. Jorda Enterprises, Inc. 277 F.R.D. 676, 687 (2012):





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