Notice of Deposition Pursuant to FED.R.CIV.P. 30(B)(6)
PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. P. 30(b)(6) and 45 and LR 30.1, [Plaintiff / Defendant] will take the deposition(s) upon oral examination, to be recorded by stenographic means and videotape, at the offices of [Deposition Location]. The deposition(s) will commence at [Date & Time]. If necessary, each deposition will be adjourned until completed.
[Plaintiff / Defendant] is requested to designate one or more 30(b)(6) witnesses who is(are) knowledgeable and prepared to testify fully on behalf of [Plaintiff / Defendant] regarding the following topics:
- Inventory of computer systems and other technology assets currently or previously in operation, including:
- Number of computer systems and other technology assets;
- Category of computer systems and other technology assets, such as servers, workstations, laptops, etc.;
- Locations of computer systems and other technology assets;
- Operating system of computer systems and other technology assets;
- Applications residing on computer systems and other technology assets;
- Corporate policies and procedures for labeling, storing, and archiving electronic information relevant to the legal matter, including:
- Physical location of electronic information;
- Inventory of backup media and archived information;
- Log of backup media and archived information;
- Schedule of when backup media and archived information was created;
- Portable media labeling techniques, including CD-ROMs, diskettes, external hard drives, tapes, etc.;
- Corporate policies and procedures for managing electronic information relevant to the legal matter, including:
- User permissions for accessing, modifying, and deleting data;
- Utilization of data deletion programs;
- Schedule for formatting hard drives or reinstalling software applications;
- Corporate policies and procedures for employee use of computers, electronic information, and technology platforms;
- Listing of current and former employees that have or had direct access to network resources, technology assets, and relevant information during the associated times in questions.
Dated: [Date]
Respectfully submitted
COUNSEL FOR [Plaintiff / Defendant]
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