Topic List

Topic List

Topic List

The topic list identifies the subjects on which the organization must produce prepared testimony. Rule 30(b)(6) requires description with reasonable particularity, and the 2020 amendment requires the parties to confer about the topics.

Objections to topic scope are raised before the deposition.

Alternative Names:

30(b)(6) Topics, Deposition Topics

Why it Matters?

Topic drafting determines the entire deposition, since the organization prepares only on what was noticed and testimony is confined accordingly. Topics that are overbroad invite objection and produce witnesses prepared superficially across too much ground, while narrow topics limit the examination. The conferral requirement gives both sides a mechanism to resolve scope before it becomes a motion, and using it is faster than litigating.

Frequently asked questions

How specific must topics be?

What does the conferral requirement accomplish?