Depositions: Rule 30(b)(6) Fact Witness ESI Deposition Outline Checklist (Federal)

Summary

This checklist provides a list of questions you may ask at a Fed. R. Civ. P. 30(b)(6) deposition of a company representative knowledgeable about the company's storage, preservation, and collection of electronically stored information (ESI) in a federal court litigation. Specifically, this checklist covers questions about the witness' qualifications, ESI habits, and preservation and collection efforts, as well as the pending litigation.