Summary
The Northern District of California denied without prejudice a joint discovery letter seeking to compel Pacific Crane Maintenance Company to reproduce its Rule 30(b)(6) witness in a maritime personal injury case. The court found that the parties had not adequately supported or explained their competing assertions concerning an employee’s files, the noticed deposition topics, and the witness’s preparation. The court ordered the parties to meet and confer and, if necessary, submit a new standalone discovery letter with supporting evidence.
Court
United States District Court for the Northern District of California
Jurisdiction
United States District Court for the Northern District of California
Decision date
July 22, 2025
Docket number
24-cv-00309-DMR
Disposition
other
Questions Presented
- Whether NYK Line adequately demonstrated that PCMC's Rule 30(b)(6) witness was insufficiently prepared because he failed to review files allegedly possessed by Andrew Lorenzana.
- Whether a Rule 30(b)(6) witness must have first-hand knowledge of the noticed topics or may prepare by reviewing information reasonably available to the organization.
- Whether NYK Line's joint discovery letter sufficiently identified the particular noticed topics and questions warranting reproduction of PCMC's Rule 30(b)(6) witness.
Holdings
- NYK Line did not make a sufficient showing that Lorenzana possessed relevant files that Baker failed to review, or that those files related to particular noticed topics; therefore, the court denied the motion without prejudice.
- A Rule 30(b)(6) witness is not required to have first-hand knowledge of the noticed topics; the witness may prepare by reviewing documents and other information reasonably available to the organization.
- NYK Line's vague assertion that Baker lacked first-hand knowledge and reviewed only prior document production did not establish inadequate preparation or justify reopening the deposition.
Court Document
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