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Well, 30(b)(6) is a type of deposition, and what you’ve done is you’ve focused on making people provide you information that they’re trying to hide, but what is really necessary to make it effective is there are a number of responsibilities that the deponent or the company that is producing the witness has to do. They have a duty to prepare. They have a duty to provide all information known to the organization, and they have to go out and gather all that institutional information and bring it together. And when they do that, we now have an opportunity to get everything they know from the mouth of the horse.
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Minnesota attorney Mark Kosieradzki discusses how Rule 30(b)(6) is a useful deposition tool.