Notice of Deposition
(FRCP Rule 30(b)(6)) (Plaintiff to Defendant)

Summary

This Notice of Deposition is for a deposition under Federal Rule of Civil Procedure 30(b)(6) by an employee seeking discovery from his or her employer in a single-plaintiff litigation in a federal district court. Rule 30(b)(6) obliges the employer to designate one or more witnesses to testify as to information known or reasonably available to the employer as an entity on each noticed topic. Under Rule 30(b)(6), the notice must define the topics for the deposition with reasonable particularity. This template includes suggested topics for a deposition in a discrimination / wrongful termination case, as well as a request for the deponent to produce documents responsive to the requests set forth in Exhibit A. Tailor the topics to the particular issues in your case as necessary. Update alert: The Trump Administration has issued two Executive Orders (EOs) EO 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” 90 Fed. Reg. 8633 (Jan. 31, 2025) and EO 14151, “Ending Radical and Wasteful Government DEI Programs and Preferencing ,” 90 Fed. Reg. 8339 (Jan. 29, 2025), through which President Trump has ordered the termination of ''diversity, equity, and inclusion'' (DEI) or ''diversity, equity, inclusion, and accessibility'' (DEIA) policies in federal agencies. Section 4 of EO 14173, entitled “Encouraging the Private Sector to End Illegal DEI Discrimination and Preferences,” directs the heads of all federal agencies, with the assistance of the Attorney General, to take appropriate action to reject DEI and DEIA programs in the private sector. The nuances of these executive orders are not yet discussed in this title. Certain DEI programs, which are statutory, particularly those related to hiring of veterans and the disabled, should not affected by these executive orders. For a discussion on the topic, see DEI in Crisis Part III: Protections for the Disabled and Veterans Still Survive, Trump Administration Revokes EO 11246, Prohibits 'Illegal' DEI: What the EO Ending Illegal Discrimination and Restoring Merit-Based Opportunity Means for Employers, and 5 Things For Private Employers To Do After Trump's DEI Order. Note, however that, on February 21, 2025, a federal judge granted a preliminary injunction blocking the administration from terminating or changing federal contracts they consider DEI-related. See Nat'l Ass'n of Diversity Officers in Higher Educ. v. Trump, 2025 U.S. Dist. LEXIS 31747 (D. Md. Feb. 21, 2025). For continued developments, see Labor & Employment Key Legal Developments Tracker (Current). For Practical Guidance Labor & Employment resources on all facets of employment litigation discovery, see Employment Litigation Discovery Resource Kit. For a full listing of key content covering depositions in employment cases, see Depositions in Employment Cases Resource Kit.