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provides courts with the discretion to limit the frequency or extent of discovery. Specifically, Rule
26(b)(2)(C) reads as follows:
(C) When Required. On motion or on its own, the court must limit the frequency or extent
of discovery otherwise allowed by these rules or by local rule if it determines that:
(i) the discovery sought is unreasonably cumulative or duplicative, or can be
obtained from some other source that is more convenient, less burdensome, or less
expensive;
(ii) the party seeking discovery has had ample opportunity to obtain the information
by discovery in the action; or
(iii) the proposed discovery is outside the scope permitted by Rule 26(b)(1).
FED. R. CIV. P. 26(b)(2)(C). Rule 30 addresses depositions by oral examination. Subpart (b)(6) sets
forth the substantive rule that applies to depositions of corporate representatives. Specifically, Rule
30(b)(6) reads as follows:
(6) Notice or Subpoena Directed to an Organization. In its notice or subpoena, a party may
name as the deponent a public or private corporation, a partnership, an association, a
governmental agency, or other entity and must describe with reasonable particularity the
matters for examination. The named organization must then designate one or more officers,
directors, or managing agents, or designate other persons who consent to testify on its
behalf; and it may set out the matters on which each person designated will testify. A
subpoena must advise a nonparty organization of its duty to make this designation. The
persons designated must testify about information known or reasonably available to the
organization. This paragraph (6) does not preclude a deposition by any other procedure
allowed by these rules.
FED. R. CIV. P. 30(b)(6).
The testimony of a Rule 30(b)(6) witness represents the knowledge of the corporation, not
the individual witness, and thus the testimony of a Rule 30(b)(6) witness is different from that of
a “mere corporate employee”; the Rule 30(b)(6) witness does not give his own personal opinions
but instead presents the corporation’s “position” on the topic. Schall v. Suzuki Motor of Am., Inc.,
No. 4:14CV-00074-JHM, 2017 WL 4050319, at *5 (W.D. Ky. Sep. 13, 2017) (quoting Richardson
v. Rock City Mech. Co., LLC, 2010 WL 711830, at *6 (M.D. Tenn. Feb. 24, 2010) (citation
omitted)); see also Jecker v. Monumental Life Ins. Co., No. 3:12-CV-219-S, 2014 WL 4063568,
at *1 (W.D. Ky. Aug. 14, 2014). When a corporation is served with a notice of a Rule 30(b)(6)
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