Kilpatrick v. Breg, Inc., 2009 WL 64358 (S.D. Fla. Jan. 9, 2009)

Key Insight: Court denied defendant?s motion to quash plaintiff?s 30(b)(6) Deposition Notice seeking a representative to answer questions regarding defendant?s document retention policies where the deposition was reasonably calculated to lead to the discovery of relevant information and where plaintiff indicated various reasons why he required the information sought, including defendant?s failure to produce any information regarding a relevant database and defendant?s claims that certain information was no longer accessible, among other things

Nature of Case: Product liability