30(b)(6) Deposition Notice: Sample, Topics, and Meet and Confer

A Rule 30(b)(6) deposition notice compels an organization to produce one or more witnesses prepared to testify about the entity’s collective knowledge on topics you define. A working sample 30(b)(6) deposition notice appears below, followed by what each element is doing and the procedural rules that surround it. Get the drafting right and the testimony binds the company; get it wrong and you invite objections, protective orders, or a witness who legitimately can’t answer your questions.

Sample Notice You Can Adapt

Swap the bracketed items for your case specifics. Every element reflects a requirement of Rule 30 or standard litigation practice.

[CASE CAPTION — full court name, parties, case number, judge]

NOTICE OF RULE 30(b)(6) DEPOSITION

PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 30(b)(6), [Plaintiff/Defendant] will take the deposition upon oral examination of [Organization Name] through one or more officers, directors, managing agents, or other persons designated to testify on behalf of [Organization Name] regarding all information known or reasonably available to [Organization Name] concerning the subject matters identified in Exhibit A, attached hereto.

The deposition will take place on [Date] at [Time] at [Location/Address], or at such other date, time, and place as the parties may agree. The deposition will be recorded by stenographic and [audiovisual/audio] means before a certified court reporter.

[Organization Name] is requested to provide written notice at least [five (5)] business days before the deposition of the name(s) and position(s) of the individual(s) designated to testify.

Pursuant to Federal Rule of Civil Procedure 30(b)(2) and Rule 34, [Organization Name] is also requested to produce at the deposition the documents and materials identified in Exhibit B, attached hereto.

[Signature Block — attorney name, bar number, firm, address, contact information]

EXHIBIT A — TOPICS FOR EXAMINATION

Topic 1: [Organization Name]’s policies and procedures for [specific subject] in effect between [Date 1] and [Date 2].
Topic 2: [Organization Name]’s investigation of [specific event], including all internal reports, findings, and conclusions prepared between [Date 1] and [Date 2].
Topic 3: The identity, roles, and responsibilities of all employees involved in [specific process or decision].
Topic 4: [Organization Name]’s communications with [specific third party or agency] regarding [specific subject] during [timeframe].

EXHIBIT B — DOCUMENTS REQUESTED

Request 1: All internal reports relating to [specific event] prepared between [Date 1] and [Date 2].
Request 2: All policies and procedures manuals for [specific department or process] in effect during [timeframe].

What Each Part of the Notice Is Doing

The caption identifies the court, parties, case number, and assigned judge. The title clearly labels the document as a 30(b)(6) notice so it isn’t mistaken for a standard individual deposition.

The naming paragraph identifies the organization as the deponent, not any specific person. This is the whole point of Rule 30(b)(6): you name the entity and the topics, and the entity picks whoever it needs to answer, whether that’s one person or five. The rule reaches public and private corporations, partnerships, associations, and governmental agencies, and the designees must testify about everything the organization knows or could reasonably find out about each listed topic.¹

The date and location paragraph states the time and place of the deposition. Reasonable written notice must go to every other party in the case.¹ The federal rules don’t fix a specific number of days as “reasonable,” and many local court rules fill that gap with requirements ranging from ten to thirty days. Check your district’s local rules before setting a date.

The recording method must appear in the notice. Options include stenographic, audio, or audiovisual recording. Most practitioners specify stenographic recording as the primary method and reserve the right to videotape as well.¹

The document-request paragraph tells the organization to bring materials. For a party organization, the notice can include a Rule 34 request for documents. For a non-party, you need a subpoena duces tecum with the materials listed in the notice or an attachment.¹ Spell out exactly what you want produced in a separate exhibit. Vague requests invite objections and delays.

Remote depositions require either a stipulation between the parties or a court order. Under Rule 30(b)(4), a remote deposition is treated as taking place where the witness answers the questions, not where the questioning attorney sits.¹ You cannot unilaterally notice a remote deposition over the other side’s objection.

Drafting the Topics for Examination

This is where most 30(b)(6) notices succeed or fail. The rule requires topics described with “reasonable particularity,” meaning each topic must be specific enough that the organization can identify what information you want and prepare the right person to testify about it.¹

A topic like “all facts relating to the plaintiff’s claim” will get objected to immediately, and rightfully so. The organization can’t reasonably prepare a witness to testify about everything. Compare that with a focused topic: “The organization’s investigation of the fire at the Springfield facility on March 15, 2025, including all internal reports and findings prepared between March 15, 2025 and June 1, 2025.” The second version tells the organization exactly what time period, what event, and what type of information you’re after.

Effective topics share several characteristics:

Bracket each topic with start and end dates instead of leaving the time period open-ended.
Name the product, facility, policy, transaction, or event rather than referencing broad categories.
Identify document types when you want testimony about internal reports, emails, or meeting minutes. The organization will know which custodians and databases to search.
Group related topics together by subject matter or chronology so the organization can assign them efficiently to designees.

Resist the urge to pile on topics that overlap or repeat the same ground with slightly different wording. Courts have little patience for notices that bury an organization under twenty-five variations of the same question. Ten to fifteen well-crafted topics usually cover more ground than thirty sloppy ones.

The Mandatory Meet and Confer

Serve the notice on the organization’s attorney, or directly on the organization if it doesn’t have counsel, using whatever method your jurisdiction requires for serving litigation documents. A 2020 amendment to Rule 30(b)(6) then adds a mandatory step: before or promptly after serving the notice, you and the organization must confer in good faith about the topics for examination.¹

This isn’t a formality. The conference is your opportunity to narrow ambiguous topics, resolve objections without court intervention, and sometimes learn which witnesses the organization plans to produce. It also signals reasonableness to the court if a dispute later arises. If you’re deposing a non-party organization by subpoena, that subpoena must advise the organization of its duty to confer with you.

When the Organization Isn’t a Party

A notice alone doesn’t reach a non-party. You need a Rule 45 subpoena, which must issue from the court where your action is pending, state the court and case information, command the organization to attend and testify, and specify the recording method.²

Geography matters for non-parties. A subpoena can only compel someone to attend a deposition within 100 miles of where they reside, work, or regularly do business in person.² Some courts have applied this 100-mile limit strictly even for remote depositions.

Service requires personal delivery by someone at least 18 years old who isn’t a party. The server must also tender the witness fee for one day’s attendance and the mileage allowed by law at the time of service.² Skip the witness fee and you’ve given the non-party grounds to quash the subpoena before anyone sits down.

Timing and Deposition Limits

A 30(b)(6) deposition counts as a single deposition of the entity for purposes of the ten-deposition-per-side limit, even if the organization produces multiple witnesses to cover different topics. You can depose five different company representatives across two days on various topics and only use one of your ten depositions. If you need more than ten depositions total across all deponents, you must get leave of court or a stipulation from the opposing party.¹

Each deposition is also capped at one day of seven hours unless the parties agree otherwise or the court grants additional time.¹ When multiple witnesses appear for different topics, courts generally apply the seven-hour cap to each witness individually, though some districts treat the entire 30(b)(6) deposition as subject to a combined limit. Check your district’s case law before assuming you’ll get seven hours per witness.

On timing, you generally cannot notice a deposition before the parties have held their Rule 26(f) discovery-planning conference. The exception is narrow: you can depose someone earlier if they’re about to leave the country and won’t be available afterward, and you certify that in the notice with supporting facts.³

What Your Notice Sets in Motion

Once the notice lands, the organization must designate one or more representatives to testify on every listed topic. Designees can be officers, directors, managing agents, or any other person who agrees to testify on the organization’s behalf.¹ The organization picks the individual, not you.

Preparation is the key obligation on the receiving side. The designee doesn’t just show up and share what they personally recall. The organization must make a good-faith effort to collect all reasonably available information on each topic by reviewing documents, interviewing current and former employees, examining prior testimony, and synthesizing it so the witness can present the entity’s knowledge coherently. A witness who repeatedly answers “I don’t know” to on-topic questions signals inadequate preparation, and courts treat that as functionally equivalent to failing to appear.

Because the witness speaks for the entity, an adverse party can use the deposition transcript at trial for any purpose without having to show the witness is unavailable.⁴ Testimony that falls within the scope of your noticed topics binds the organization. If the designee admits the company knew about a safety defect, that admission belongs to the company, not just to the individual who said it. Answers on questions that go beyond the noticed topics are generally treated as the personal knowledge of the individual witness, not as binding admissions of the entity. That is why drafting your topics broadly enough to capture the testimony you actually need, while still meeting the reasonable-particularity standard, is the single most important drafting decision you make.

1
Legal Information Institute. Federal Rules of Civil Procedure Rule 30 – Depositions by Oral Examination
2
Legal Information Institute. Federal Rules of Civil Procedure Rule 45 – Subpoena
3
Legal Information Institute. Federal Rules of Civil Procedure Rule 26 – Duty to Disclose; General Provisions Governing Discovery
4
Legal Information Institute. Federal Rules of Civil Procedure Rule 32 – Using Depositions in Court Proceedings