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Beldar

Corporate designees are also, in theory, required to make themselves knowledgeable before testifying, if they're not already. Even more lawyers ignore that little bit of the rules. It's almost always a tactical mistake to present a witness whose answers on the designated topics are, "I dunno, I dunno."

If the case will bear the investment of time and money, it's always fun to get the designated rep's depo, then individually notice the other names that have popped up in depo testimony, documents (especially organizational charts), and interrogatory answers. The contrast between what they know and what the designated rep admitted to can be great fodder for a "cover-up" meme — regardless of whether you're pitching that to the judge in trying to compel more discovery or get sanctions, or impeach the corporation's credibility with the ultimate factfinder.

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