Checklist · Class Actions / Representative Proceedings
Deposition outline: class representative and Rule 30(b)(6)
Question outline for the deposition of a proposed class representative and for a Rule 30(b)(6) deposition on the systems that define the class. Questions only. No script of testimony.
- Kind
- Checklist. Steps or checks to work through and tick off.
- Where it applies
- United States
- AI use
- Yellow You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at
- 22 October 2026
- Status
- Maintained. Checked on 22 October 2026 against the 3 authorities it cites, for United States.
- Version
- 1
- Source
- Written for this library
When to use it
Use to prepare those depositions in a putative federal class action. Do not convert the outline into the representative's declaration or affidavit. Do not add topics the Rule 30(b)(6) notice did not describe.
Used for these tasks
- Draft the group or class definition from the claim theory
- Compile the court book and a hearing chronology
- Build a viability memo: cause of action, class size and common questions
Each task page says how far AI may help with the task and what the lawyer must review.
How AI may be used
AI may group questions under Rule 23(a) topics and under the noticed 30(b)(6) matters. The lawyer decides what is asked. The tool writes no answer.
AI may
- Sort the lawyer's objectives into typicality, adequacy, and the class definition
- Build the 30(b)(6) section only from topics in the notice the lawyer provides
- List questions that ask the witness to state a legal conclusion, for the lawyer to remove
AI must not
- Must not draft the representative's testimony, declaration or affidavit
- Must not add a 30(b)(6) topic that is not in the notice
- Must not assert that the proposed representative is adequate or typical
The lawyer checks
- The outline matches the pleaded definition and the notice
- Conferral on the 30(b)(6) topics is done or diarised, as Rule 30(b)(6) requires
- The outline is not given to the witness as a script
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
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More in Class Actions / Representative Proceedings
- First case management hearing: costs disclosure and readiness note (Federal Court class action)
- Opt-out notice, notice distribution plan and settlement-notice checklist (Federal Court class action)
- Retainer letter and conditional costs agreement for a representative applicant (Federal Court class action)
- Class-action litigation hold notice
- Competing class actions: comparison note for the carriage or selection hearing
- Litigation funding agreement and costs review checklist (including common fund orders and Victorian group costs orders)
- Pre-filing memo: Part IVA threshold requirements and class definition
- Rule 26(f) report for a putative class action
- Opt-out register against the Court's date and Form 21 (Federal Court class action)
- Settlement approval application checklist (Federal Court class action, s 33V and GPN-CA)
- Settlement distribution scheme (with safeguards for technology-assisted claims assessment)
- Stipulated protective order for class-member data
- Periodic update letter to group members (clients and registered group members)
- Letter to the respondent's lawyers about communications with class members
- Opt-out notice distribution plan (Federal Court class action, GPN-CA Part 12)
- Group costs order: comparison note before a Victorian s 33ZDA application
- Group member registration and intake protocol (including AI triage of registrations)
- Prompt template with guardrails: reconciling registrations to the class definition
All precedents for Class Actions / Representative Proceedings · Tasks and AI use in this area