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Thought Leadership

Speaker, "Hot Topics for the Person Most Qualified Under California Law and Federal Law," Santa Clara County Bar Association

Speaking Engagements

Tyler Paetkau will present, "Hot Topics for the Person Most Qualified Under California Law and Federal Law," at the Santa Clara County Bar Association on Thursday, May 16, 2024.

In this webinar, the panel will address “hot” issues with Rule 30(b)(6) depositions of an entity or organization.


  • The differences between Federal Rule of Civil Procedure 30(b)(6) and PMQ depositions under the California Code of Civil Procedure. 
  • Describing with reasonable particularity the matters on which examination is requested under Code Civ. Proc. § 2025.230. 
  • Selecting the Rule 30(b)(6) or PMQ witness or witnesses – see Code Civ. Proc. § 2025.230: Entity “shall designate and produce at the deposition those of its officers, directors, managing agents, employees, or agents who are most qualified to testify on its behalf as to those matters to the extent of any information known or reasonably available to the deponent.” 
  • Objecting to Rule 30(b)(6) and PMQ notices, and protective orders. 
  • Obligations and options if no current employee is personally knowledgeable and addressing topics seeking information that the company does not possess. 
  • Admission of hearsay in Rule 30(b)(6) and PMQ depositions. See Ramirez v. Avon. 
  • Deposition questions outside the scope of the notice. 
  • Issues unique to employment claims may affect how counsel prepares to take or defend a Rule 30(b)(6) / PMQ depositions. 
  • Risks of designating a lawyer, or someone else with extensive privileged information, as a Rule 30(b)(6) / PMQ witness. 

For more information, visit the event website.