Appendix 14

• Author: Kenneth Dorsney
• Pages: 625-627

625

PLA IN TI FF ’S NOT IC E OF DE PO SI TIO N WITH SCH ED UL E A

IN THE UNITED STATES DISTRICT COURT

[Name of District]

[DISTRICT COURT CAPTION]

PLAINTIFF’S NOTICE OF DEPOSITION OF

[NAME OF DEFENDANT] PURSUANT TO FED. R. CIV. P. 30(b)(6)

PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of

Civil Procedure, and the applicable Local Rules of the United States District Court for the

District of [Name of District], plaintiff [Name of Plaintiff] (“Plaintiff”), by its attorneys,

will take the deposition upon oral examination of [Name of Defendant] (“Defendant”),

which shall designate one or more officers, directors or other persons who consent to

testify on its behalf about matters set forth in the attached Schedule A, including

information in the possession, custody and control of Defendant.

The deposition will begin at [TIME], on [DATE], at the offices of [Name of

Counsel for Plaintiff] at [Address of Counsel for Plaintiff]

The deposition will take place upon oral examination, pursuant to the Federal

Rules of Civil Procedure, before an officer duly authorized by law to administer oaths

and record testimony. The testimony will be recorded by stenographic means and will

also be videotaped. The deposition will continue from day to day if necessary until

completed or adjourned. Separately for each numbered area of examination in the

attached Schedule A, Defendant shall identify to Plaintiffs, no later than 7 days before the

date of the deposition, the person(s) designated to testify on Defendant’s behalf.

DATED: [Date of Signature]

[Name of Counsel for Plaintiff]

[Name of Attorney for Plaintiff]

[Address of Counsel for Plaintiff]

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