The plaintiff, Chrimar Systems Inc. and Chrimar (“Chrimar”) filed a motion to compel an additional deposition of Defendant D-Link Systems, Inc.’s (“D-Link”) corporate representative, William C. Brown. Chrimar previously took the deposition of D-Link’s corporate representative, pursuant to Federal Rule of Civil Procedure 30(b)(6).
After the deposition concluded, Mr. Brown supplied an errata sheet, correcting numerous portions of his deposition testimony pursuant to Federal Rule of Civil Procedure 30(e). In its motion, Chrimar contends that over 60 answers were materially altered and several answers were changed from “yes” to “no.” As a result, Chrimar moved the district court to compel “Mr. Brown for a second deposition in Dallas, Texas regarding the changes represented in his errata sheet.”