Objections and Responses to Notice of Rule 30(b)(6) Deposition
(MA)

Summary

This template objections and responses to a notice of Rule 30(b)(6) deposition is for use by counsel for a corporate, government, or other similar entity in civil litigation that may be used in a Massachusetts state court (Superior or District Court) case. It contains practical guidance, drafting notes, and alternate clauses. You may object to a Rule 30(b)(6) notice of deposition if it does not meet the applicable requirements, such as if it fails to properly identify the entity to be deposed or does not define the topics for the deposition with reasonable particularity. This template assumes that the defendant is the responding party, but the plaintiff may also be the subject of a 30(b)(6) deposition. For more on defending Rule 30(b)(6) depositions, see Depositions: Defending Rule 30(b)(6) Deposition of an Entity Checklist (MA). For a related checklist, see Deposition Objections Checklist (MA).