Depositions of a corporate designee pursuant to Federal Rule of Civil Procedure 30(b)(6) have the potential to be very useful, even for the party defending the deposition. It’s an opportunity for the company to put its position on the record and clarify issues that would otherwise remain hazy if left only to traditional fact witnesses. That opportunity can be squandered, however, if you are not prepared for the deposition or try to thwart the deposition because of the scope of the questions asked.
If you want to take full advantage of the opportunity, here are three things to avoid: