Using 30(b)(6) Depositions to Neutralize RFP Obstruction in Discovery

Responses to Document Requests and ESI Discovery are often littered with objections and incomplete answers. Rule 30(b)(6) depositions can be used to identify important documents and create a bulletproof record to virtually ensure you will win your motions to compel. This program will arm you with a 30(b)(6) deposition protocol to cut through the obstructive nonsense, neutralize objections before they happen, and get what you need.  

Mark R. Kosieradzki, author of 30(b)(6): Deposing Corporations, Organizations, & the Government and the new book Litigation Obstruction: Breaking Through,  AAJ Press 2024, will show you how to structure your document/ESI discovery, craft your 30(b)(6) notice and learn to take the deposition by seeing video clips of actual depositions to walk you through the steps. 

Praise for Mark's new book Litigation Obstruction: Breaking Through

Have you ever felt like lawyers on the other side of your lawsuit are withholding information, documents, and evidence? Being dishonest? Frustrating the efforts to get the evidence for your case? Mark’s book Litigation Obstruction: Breaking Through has your answers. This book, with great precision, helps you understand how to cut through evasive, dishonest, and unethical discovery responses.
Litigation Obstruction: Breaking Through will not only provide you with solutions to 99% of the problems you face in discovery but also arm you with clear cut, distinct tactics for getting the evidence you need. It doesn’t matter how many years you have been practicing law. Whether you are a new lawyer or someone who has been in the area for decades, this book has great lessons on how to overcome adversity from the unrelenting opposition. Every lawyer needs Mark’s litigation obstruction book to fight the next obstreperous, dishonest, and evasive lawyer that they are likely to encounter in the future.  Mark’s book is the bible for fighting misleading, untruthful and obstructive tactics.

Lisa Blue Baron JD PhD
AAJ President  2014-2015
Author Thinking Outside the Box in the Courtroom: Voir dire

Litigation Obstruction: Breaking Through is a revolutionary masterclass in how to navigate the increasingly daunting world of litigation where obstruction on both sides occurs in far too many cases. I know that - having presided over more than 3,500 civil cases in seven different federal courts from M.D. Florida to the District of the N. Mariana Islands. This book is living proof in every chapter of what I have come to appreciate in nearly five decades as a trial lawyer, federal district judge, and now a mediator and arbitrator: those who master civil procedure Rule the World of litigation. Mr. Kosieradzki has long been known not only as a leading national expert on navigating civil procedure but as THE leading civil trial lawyer who has the unsurpassed ability to takes the high road while busting through the blizzard of obstruction of all kinds. The book is uber comprehensive and contains critical and unique bonus appendices that compares case law from every state and federal jurisdiction. These appendices alone are worth their weight in gold many times over. No law firm or lawyer that practices in litigation from fender benders to complex class actions should be without this book. If I had to choose just one book to be in my personal law library – without question – it would be Litigation Obstruction: Breaking Through.  Thank you. Mr. Kosieradzki, for your willingness to share your life’s professional work, insights, and passion in this unparalleled groundbreaking book. The legal profession owes you a huge debt of gratitude.

Hon. Mark W. Bennett (Ret. U.S. District Judge)
Director, Institute for Justice Reform & Innovation
Drake University Law School