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Barry M. Klayman and Mark E. Felger

Can a party be precluded from offering evidence that contradicts or seeks to expand the testimony of its designated Rule 30(b)(6) witness? When a party notices the deposition of an organization under Rule 30(b)(6), the organization has an obligation to ensure, through the testimony of one or more witnesses, that the party taking the deposition receives complete responses, based on the organization’s full knowledge and any relevant material available to it.

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