30(b)(6) Depositions Unveiled: The Ultimate Guide for Plaintiff and Defense Attorneys

David Taubenfeld | Haynes and Boone, LLP

David Taubenfeld represents policyholders in every kind of dispute they may have with their insurers. He finds coverage where others may not look, and he attempts to secure coverage for his clients through negotiation and diplomacy before litigation becomes necessary. When litigation becomes necessary, he litigates aggressively, always with the goal of securing coverage for his clients quickly and economically. He has secured millions of dollars in coverage for his clients through negotiation and litigation.

David represents corporate and individual insureds in coverage and bad-faith lawsuits and arbitrations against insurance carriers under Directors’ and Officers’ Liability, First Party Property/Business Interruption, Errors and Omissions, Professional Liability, General Liability, Fidelity Surety Bonds, Performance and Payment, Primary, Excess, and Umbrella insurance policies.

David also litigates construction matters for architects, engineers, contractors and owners. He litigates both the construction disputes themselves and any insurance coverage matters related to his construction work.

LinkedIn: https://www.linkedin.com/in/david-taubenfeld-85052b9/

Natalie DuBose | Haynes and Boone, LLP

Natalie DuBose is an insurance-recovery professional who has successfully represented a number of businesses—large and small— under all types of commercial insurance policies, including directors and officers, commercial general liability, property, errors and omissions, builder’s risk, fidelity, and cyber. Natalie has a decade of experience helping businesses navigate complex insurance disputes. Natalie has developed a business-oriented approach to insurance recovery and a unique understanding of her clients’ goals, and actively consults with clients on cost-effective solutions to manage risk and maximize insurance recovery.

Natalie has worked with dozens of clients in the financial services, construction, and healthcare sectors to recover under claims following significant litigation events or natural disasters. Natalie has consistently shown a track record of success in representing corporate policyholders in coverage disputes in state and federal courts across Texas and beyond, and in arbitrations, mediations, and appeals at the state and federal level.

Natalie has been recognized in the Best Lawyers in America for Insurance Law every year since 2019, and has been recognized as a Rising Star in Insurance by Texas Super Lawyers. She is the Chair of the Dallas Bar Association’s Tort and Insurance Practice Section, where she has served as a board member since 2016. She has chaired many ABA insurance conferences, and is a regular speaker and writer on insurance topics, including for the Texas Insurance Law Journal and the Texas Bar Advanced Insurance Law seminar.

LinkedIn: https://www.linkedin.com/in/natalie-dubose/

Alexander Clark | Haynes and Boone, LLP

Alex Clark is an insurance coverage and business litigator whose experience advising and representing clients, including commercial policyholders, in coverage and contractual disputes contributed to his recognition as “One to Watch” in commercial litigation by The Best Lawyers in America directory published by Woodward/White, Inc. from 2023 – 2025. He joined the firm after a two-year clerkship with U.S. District Judge Lee Yeakel in Austin, Texas. Alex is co-chair of the firm’s Military, Veterans, and Partners (MVP) Inclusion Network and serves as one of its forty Wellness Champions.

Alex graduated from the University of Texas School of Law with Honors and was as an Associate Editor of the Texas Law Review. During law school Alex was a co-founder of the Texas Law Veterans Association, President of the Texas Law Democrats, and a Contracts teaching assistant. In addition to his coursework, Alex interned for Travis County District Judge Jan Soifer, the Texas Civil Rights Project, and the U.S. Attorney’s Office for the Western District of Texas.

In 2012, Alex graduated with honors from Austin College, where he served as president of the Student Assembly. Before law school, Alex taught third grade in San Antonio as a Teach for America corps member and served as the Non-Commissioned Officer in Charge (NCOIC) of Current Intelligence for the 433rd Air Wing at Lackland AFB.

When not serving his clients, Alex is dedicated to continuing a life of service. Alex stays active registering voters as a Volunteer Deputy Registrar for Dallas County and continues to mentor prospective Teach for America corps members, veterans seeking to become law students through Service to School, and clerkship applicants from diverse backgrounds through Law Clerks for Diversity.

LinkedIn: https://www.linkedin.com/in/alexandermclark/

I. Understanding rule 30(b)(6) and its strategic use | 2:00pm – 2:40pm

• The purpose and scope of rule 30(b)(6) depositions
• Selecting and preparing the right corporate representative
• Notice requirements: Drafting effective deposition notices
• Common objections and challenges to 30(b)(6) notices

II. Conducting and defending the 30(b)(6) deposition | 2:40pm – 3:30pm

• Best practices for examining the corporate representative
• Avoiding common pitfalls and deficient testimony

Break | 3:00pm – 3:10pm

• Tactics for objecting and protecting your client
• Reconciling individual witness testimony with 30(b)(6) testimony

III. Post-deposition considerations and leveraging testimony at trial | 3:30pm – 4:10pm

• Using 30(b)(6) testimony in summary judgment and trial
• Handling inconsistent or contradictory testimony
• Motions to compel and sanctions for non-compliance
• Recent case law and emerging trends in 30(b)(6) depositions