Previously I wrote about what is a 30(b)(6) deposition and why do you want one, and I noted in another article about a TCPA plaintiff getting the run around that a foundational 30(b)(6) deposition might be useful. But what is a foundational 30(b)(6) deposition? A foundational 30(b)(6) deposition is typically done at the outset of a lawsuit and it isn't intended to get into the merits of the lawsuit, but to understand organization structure, how and where documents are retaine