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Deposing the Ventriloquist's Dummy: Strategic Insights for Deposing Corporate Entities in Legal Proceedings

Updated: Sep 23

a jointed wooden model with strings attached and a hand controlling it'smovements

Strategies for Deposing Corporate Entities

Paul Gold's presentation, "Deposing the Ventriloquist's Dummy," is a crucial resource for legal professionals focusing on deposing corporate entities. It provides an in-depth look at the intricacies involved in deposing corporate representatives, a common yet challenging aspect of legal proceedings. Gold discusses the importance of understanding the Federal Rules of Civil Procedure, particularly Rule 30(b)(6), and emphasizes the need for precise and strategic questioning to effectively gather information from corporate entities.


Key takeaways from the presentation include:

  • Techniques for crafting precise deposition notices.

  • Strategies for ensuring comprehensive and relevant corporate testimony.

  • Understanding the obligations of corporate entities in depositions.

  • Navigating the complexities of corporate knowledge and representation.

  • Leveraging deposition insights for trial preparation and strategy.


This presentation is an essential guide for attorneys seeking to enhance their skills in deposing corporate representatives. It offers practical advice and strategies that can be immediately applied in legal practice.


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