Rule 30(b)(6) depositions in Nevada: how an organization testifies, and what the record looks like

What NRCP 30(b)(6) says

The whole rule is one paragraph, and it repays a careful read. NRCP 30(b)(6): "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. Rule 30(b)(6) does not preclude a deposition by any other procedure allowed by these rules."

Three things follow from that text. First, the deponent is the organization, not the individual in the chair. Second, the noticing party controls the topics and the organization controls the choice of speaker. Third, the designee's job is to testify about what the organization knows or can reasonably find out, not merely what the designee personally remembers.

The last sentence matters too. A Rule 30(b)(6) notice does not use up a party's right to depose the organization's officers or employees as individuals under the ordinary procedure, and those individual depositions are counted separately for the 10-per-side limit in NRCP 30(a)(2)(A)(i).

The notice: topics described with reasonable particularity

The notice carries everything an ordinary deposition notice must contain under NRCP 30(b)(1): not less than 14 days' written notice to every other party, the time and place, and, under NRCP 30(b)(3)(A), the method of recording, with the noticing party bearing the recording costs. If documents are demanded by subpoena duces tecum, the materials must be listed in the notice or an attachment (NRCP 30(b)(2)), and a notice to a party deponent may be accompanied by a Rule 34 request to produce at the deposition.

What is special about a Rule 30(b)(6) notice is the topic list. The rule requires the noticing party to "describe with reasonable particularity the matters for examination." The organization reads that list to decide whom to designate and what to prepare each designee on, so the list is in practice the outline of the deposition.

In Clark County, Administrative Order 22-08 of the Eighth Judicial District Court repeats the requirement that the notice "must describe with reasonable particularity the matters for examination," and it sets out what an objecting organization must do, discussed below.

From the scheduling desk: send us the topic list with the booking when you can. The number of topics and designees tells us how many days to hold, whether to assign a second reporter, and how many exhibit sets to expect.

The organization's duty: designate, prepare, and be bound

Once served, the organization "must then designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on its behalf." It may also "set out the matters on which each person designated will testify," which is how a company splits a long topic list among several witnesses. A nonparty organization served with a subpoena must be told of this duty; the rule says "A subpoena must advise a nonparty organization of its duty to make this designation."

The designee's knowledge standard is the organization's, not the individual's: "The persons designated must testify about information known or reasonably available to the organization." That is why a designee is expected to have prepared, and why a designee who answers "I personally don't know" to a noticed topic can create problems for the organization.

Administrative Order 22-08 states the Clark County position on what the organization owes. The entity "must only prepare the designee and be willing to be bound by the designee's testimony." The order also rejects a label that appears on many notices: it says "There is no such type of deposition recognized under the NRCP" as a "PMK" deposition taken "for the purpose of binding the entity." A notice that asks for the "person most knowledgeable" is, under the NRCP, either a Rule 30(b)(6) notice with topics or an ordinary notice of an individual, and the order treats the Rule 30(b)(6) designation as the mechanism that binds the entity.

No meet-and-confer sentence in the Nevada text, and the Clark County gloss

Attorneys who also practice in federal court will notice something missing. In 2020, FRCP 30(b)(6) was amended to add that "the serving party and the organization must confer in good faith about the matters for examination." The Nevada rule was restyled in 2019 under ADKT 0522 and has not been amended since, so the NRCP 30(b)(6) text contains no confer requirement.

Clark County fills part of that gap by administrative order. Administrative Order 22-08 provides that "Parties who object to the number or description of topics for examination must confer in good faith promptly upon the service of the subpoena or notice," a gloss the order supports by citing the 2020 federal committee note. The order goes further on remedies: an entity objecting to topics "must also seek and obtain a protective order from the Court before going forward with the deposition." Objecting in a letter and then refusing to produce a witness on the disputed topics is not the procedure the order contemplates.

The order also addresses questions that stray outside the noticed topics. Beyond-scope questions may not be the basis of an instruction not to answer, which is consistent with NRCP 30(c)(2), under which an instruction not to answer is proper only to preserve a privilege, to enforce a court-ordered limitation, or to present a Rule 30(d)(3) motion. Instead, counsel for the organization "may note on the record that ... the answers will not bind the entity." The question is answered, the objection is on the transcript, and the effect is sorted out later.

Outside Clark County, none of this gloss exists in a local rule. The Second Judicial District Court's WDCR contain no rule that mentions depositions at all and no counterpart to Administrative Order 22-08; in Washoe County, disputes over a Rule 30(b)(6) notice go to the discovery commissioner under WDCR 24 on the text of the NRCP alone.

Any motion about a Rule 30(b)(6) dispute in Clark County goes first to the discovery commissioner under EDCR 2.34, which also requires an affidavit that counsel conferred, or tried in good faith to confer, before the motion is filed.

Counting a Rule 30(b)(6) deposition: one deposition, but seven hours per designee

NRCP 30 itself does not say how a multi-designee deposition counts against the 10-per-side limit in NRCP 30(a)(2)(A)(i) or the "1 day of 7 hours of testimony" in NRCP 30(d)(1). In Clark County, Administrative Order 22-08 answers both questions in the same passage: "If an entity designates more than one spokesperson under Rule 30(b)(6), the designees collectively count as one deposition toward the presumptive maximum of ten depositions per side. ... 'for purposes of this durational limit, the deposition of each person designated under Rule 30(b)(6) should be considered a separate deposition.' In other words, the deposing party may depose each designee for up to 7 hours in 1 day."

So in Clark County a company that designates three witnesses has given one deposition for counting purposes, but the noticing party may examine each of the three for up to seven hours on the record. The seven hours are measured as the 2019 committee note to Rule 30 describes: "7 hours on the record," with convenience breaks, meal recesses and Rule 30(d)(3) adjournments excluded. The order restates that reading.

This counting rule comes from the Clark County order, not from the NRCP text, and Washoe County has no equivalent order. In a case outside the Eighth Judicial District, ask your attorney how the court counts designees before relying on either side of it.

Where the designee is deposed, and whether it can be remote

Administrative Order 22-08 sets a default location rule for Clark County: "Generally, a plaintiff's deposition may be taken in this District; a defendant's deposition may be taken where the defendant resides or, in the case of a corporate defendant's Rule 30(b)(6) designee, where the corporation has its principal place of business." For an out-of-state corporate defendant, that default points away from Las Vegas unless the parties agree otherwise.

The order also says that "Normally, a deposition will take place in person," and that "The parties may stipulate, and the Court may order for good cause shown, that a deposition 'be taken by telephone or other [including video] remote means.'" The good-cause factors come from Okada v. Eighth Jud. Dist. Ct., 131 Nev. 834, 359 P.3d 1106 (2015). The statewide basis for a remote deposition is NRCP 30(b)(4), under which the parties may stipulate, or the court may order on motion, that a deposition be taken by remote means, and "the deposition takes place where the deponent answers the questions."

In practice, Rule 30(b)(6) depositions of out-of-state companies in Las Vegas cases are often taken remotely by stipulation. In Clark County the order's remote-document rules then apply: the examiner "must contemporaneously provide all participants with electronic copies of any document used at the deposition" and "must display a document on the video feed during a remote video deposition while questioning the witness about the document," and exhibits "must be disclosed prior to the deposition." Our guide to remote depositions under Nevada rules covers the stipulation, the oath and the location questions.

Subpoenaing a nonparty organization

A party organization is compelled by the notice. A nonparty organization, such as a vendor, a bank or a former employer, is compelled by a subpoena under NRCP 45, and the Rule 30(b)(6) sentence quoted above requires that subpoena to "advise a nonparty organization of its duty to make this designation."

The subpoena must meet the ordinary Rule 45 requirements. Under NRCP 45(a) it must state the issuing court, the title and case number, the name and address of the responsible party or attorney, and the command to attend and testify at a specified time and place, and it must "set out the text of Rule 45(c) and (d)." A subpoena commanding attendance at a deposition "must state the method for recording the testimony." Service may be made by any person at least 18 years old who is not a party, and if attendance is required "the serving party must tender the fee for 1 day's attendance and the mileage allowed by law" (NRCP 45(b)(1)). Our guide to deposition subpoenas in Nevada covers the fee, the 100-mile rule, documents, objections and out-of-state cases.

Using a designee's deposition at trial

A Rule 30(b)(6) deposition is unusually powerful at trial because of NRCP 32(a)(3): "An adverse party may use for any purpose the deposition of a party or anyone who, when deposed, was the party's officer, director, managing agent, or designee under Rule 30(b)(6) or 31(a)(4)." The adverse party does not need to show that the designee is unavailable; the designee's testimony can be read or played as substantive evidence against the organization.

The general conditions in NRCP 32(a) still apply: the party against whom it is used must have been "present or represented at the taking of the deposition or had reasonable notice of it," and the testimony is used "to the extent it would be admissible under Nevada law of evidence if the deponent were present and testifying." Under NRCP 32(c), the offering party must provide a transcript of any deposition testimony it offers, and in a jury trial, on any party's request, testimony offered for a purpose other than impeachment "must be presented in nontranscript form, if available," which is why many Rule 30(b)(6) depositions are video recorded. Our guide to using deposition transcripts and video at trial in Nevada covers Rule 32 in full.

Preparing the reporter for a Rule 30(b)(6) record

From the court reporter's chair, a Rule 30(b)(6) deposition differs from an individual deposition in volume and structure more than in law. These are the things that make the record cleaner, drawn from reporting organizational depositions in Las Vegas since 1990.

• Tell us how many designees are expected and whether they testify on one day or several. Each designee is sworn separately, and the reporter notes on the record when one is excused and the next takes the oath. Expect the officer to open with the on-the-record statement NRCP 30(b)(5)(A) requires, including the identity of everyone present.
• Send the topic list and the caption in advance. Designees are often asked which topics they cover, and spellings of company names, products and acronyms improve when we have seen them first.
• Plan the exhibits. Organizational depositions carry heavy document sets, and NRCP 30(f)(2) lets any party request that documents produced during the deposition be marked and attached. For a remote deposition in Clark County, remember the electronic-copy and video-feed rules above.
• Consider realtime. A live feed to counsel's laptops helps when several attorneys are tracking which answers were given on which topic, or when a designee is examined across sessions.
• Decide on video at the notice stage. Because NRCP 32(a)(3) lets the adverse party use the designee's deposition for any purpose, and NRCP 32(c) favors nontranscript form in jury trials, many parties notice audiovisual recording alongside the stenographic record. Under NRCP 30(b)(5)(B) the officer repeats the opening items at the start of each unit of the recording, and the witness's and attorneys' "appearance or demeanor must not be distorted through recording techniques."
• Book the room, the interpreter and the remote link early. Our conference rooms are available for multi-day organizational depositions, interpreters are arranged by referral, and remote and hybrid setups are tested before the record opens.

We staff Rule 30(b)(6) depositions with stenographic and voice-writing reporters, all certified by the Nevada Certified Court Reporters' Board, across the Las Vegas valley.

Currency of this guide

This guide reflects the NRCP as amended through October 31, 2025; NRCP 30, 32 and 45 were last amended effective March 1, 2019 (ADKT 0522). The federal comparison is to FRCP 30 as of December 1, 2025. Administrative Order 22-08 (dated May 9, 2022) is listed on the Eighth Judicial District Court's administrative-order index with no amending order as of October 2026; EDCR and WDCR are stated as amended through October 31, 2025. Confirm the current text with your attorney before relying on any of it.

Common questions

What is a Rule 30(b)(6) deposition?

A deposition in which the deponent is an organization, such as a corporation, partnership, association or governmental agency. Under NRCP 30(b)(6) the noticing party describes the matters for examination with reasonable particularity, and the organization designates one or more people to testify on its behalf about information known or reasonably available to it.

Is a "PMK" or "person most knowledgeable" deposition the same thing?

Not under the Nevada rules. The Eighth Judicial District Court's Administrative Order 22-08 states that there is no such type of deposition recognized under the NRCP for the purpose of binding the entity. The organization's obligation is to prepare a designee under Rule 30(b)(6) and be willing to be bound by that designee's testimony.

Does Nevada require the parties to meet and confer about 30(b)(6) topics?

The NRCP 30(b)(6) text does not; the confer-in-good-faith sentence added to the federal rule in 2020 is absent from the Nevada rule. In Clark County, Administrative Order 22-08 requires parties who object to the number or description of topics to confer in good faith promptly after service, and an objecting entity must obtain a protective order before going forward.

If a company designates three witnesses, is that one deposition or three?

In Clark County, Administrative Order 22-08 says the designees collectively count as one deposition toward the 10-per-side limit, but each designee may be deposed for up to 7 hours in 1 day. That counting rule is the Clark County order's, not the text of NRCP 30; ask your attorney how it applies in another district.

Where is a corporate defendant's designee deposed?

Administrative Order 22-08 states the Clark County default: a defendant is deposed where the defendant resides, or, for a corporate defendant's Rule 30(b)(6) designee, where the corporation has its principal place of business. The parties may stipulate to a remote deposition under NRCP 30(b)(4), or the court may order one on motion for good cause.

Can the designee refuse to answer a question outside the noticed topics?

Under NRCP 30(c)(2) an instruction not to answer is proper only to preserve a privilege, to enforce a court-ordered limitation, or to present a Rule 30(d)(3) motion, and Administrative Order 22-08 says beyond-scope questions may not be the basis of an instruction not to answer. Counsel may instead note on the record that the answers will not bind the entity.

How can the other side use the designee's testimony at trial?

Under NRCP 32(a)(3), an adverse party may use for any purpose the deposition of anyone who, when deposed, was the party's designee under Rule 30(b)(6), subject to the general conditions in NRCP 32(a). The offering party must provide a transcript, and in a jury trial testimony offered for a purpose other than impeachment must be presented in nontranscript form if available, on any party's request (NRCP 32(c)).