Deposition Questions
(Discrimination, Harassment, or Retaliation) (Plaintiff to Rule 30(b)(6) Employer Witness)

Summary

These template Deposition Questions (Plaintiff to Rule 30(b)(6) Employer Witness) (Discrimination, Harassment, or Retaliation) provides sample questions that a plaintiff’s attorney can ask an employer’s Fed Civ. P. Rule 30(b)(6) witness in a discrimination, harassment, or retaliation claim. A Rule 30(b)(6) deposition is a deposition of an employer in which an employer’s representative’s testimony is imputed to the employer itself. This template contains practical guidance and drafting notes. The deposition questions set forth in this template are provided by way of example only and you should tailor them to the allegations in each particular case. You should follow up each question with appropriate further inquiry. This template is based on federal law and does not address all potential state law distinctions; thus, you should check any relevant state and local laws and review all discovery rules applicable to the jurisdiction in which your case is pending. For more information on taking depositions of Rule 30(b)(6) employer witnesses in employment cases, see Rule 30(b)(6) Deposition Strategies for Employee-Plaintiffs in Employment Cases. Also see Deposing & Examining Emp. Witnesses § 9:07—The Scope of Questioning at a Rule 30(b)(6) Deposition and Deposing & Examining Emp. Witnesses 9.II—Deposition of Rule 30(b)(6) Corporate Representative About Electronically Stored Information. For a sample Rule 30(b)(6) deposition notice, see Notice of Deposition (FRCP Rule 30(b)(6)) (Plaintiff to Defendant). For a full listing of key content covering depositions in employment cases, see Depositions in Employment Cases Resource Kit. [>] Videos. For a video suite on employment litigation depositions, see Depositions of Plaintiff Employees Video, Depositions of Supervisory Witnesses Video, and Depositions under Rule 30(b)(6) in Employment Cases Video.