Defending the Municipal 30(b)(6) in Monell Cases: Notice, Designation, and Damage Control

Shannon T. O’Connor, Partner | Kenney Shelton Liptak Nowak LLP

Shannon T. O’Connor is a Partner at Kenney Shelton Liptak Nowak LLP, where she defends municipalities, police departments, school districts, and public officials in government litigation, with nearly 65 federal cases in the United States District Courts of New York and multiple appeals before the Second Circuit Court of Appeals. Her civil rights defense work centers on Section 1983 claims, Fourth Amendment unlawful search and seizure and excessive force claims, and First Amendment retaliation claims, and includes several no-cause verdicts on civil rights claims against public officials. Her cases of first impression have been instrumental in shaping policies on police use of force, school searches, workplace compliance, and civil service law.

• Education & Credentials

Ms. O’Connor earned her J.D. from Syracuse University College of Law and her B.A. in History and Women’s Studies from the State University of New York, University at Buffalo. She is admitted to practice in New York State, in the United States District Courts for the Eastern, Northern, Southern, and Western Districts of New York, and before the United States Court of Appeals for the Second Circuit.

• Recognition & Leadership

She holds a Martindale-Hubbell AV Preeminent peer review rating and was selected to Super Lawyers in 2024 after being named to Upstate New York Super Lawyers Rising Stars from 2016 to 2020. The International Municipal Lawyers Association recognized her with the Marvin J. Glink Award in 2018 and the Amicus Service Award in 2019, and she serves as an IMLA Local Government Fellow. She was also named to the Irish Legal 100 in 2018 and received the Community Service Appreciation Award from the City of Syracuse Neighborhood Watch Association in 2011.

• Professional Involvement

Ms. O’Connor serves as New York State Co-Chair of the International Municipal Lawyers Association and is a Fellow of the organization. She is a member of the Northern District of New York Federal Court Bar Association, the New York State Bar Association, and the Women’s Bar Association of the State of New York, and is a past President, Vice President, and Secretary of the Central New York Women’s Bar Association.

• Experience

With more than 15 years of experience in municipal law, government litigation, constitutional law, employment law, and school law, Ms. O’Connor represents municipalities, school districts, police departments, teachers, administrators, private entities, and non-profit organizations from the trial courts through the appellate level. Beyond civil rights defense, her practice includes Title VII workplace and employment discrimination matters, wrongful termination, age, race, gender, and disability discrimination claims, sexual harassment and retaliation claims, Civil Service Law §75 disciplinary hearings for public employees, whistleblower retaliation defense, and internal investigations of unlawful discrimination and prohibited workplace conduct. She appears before the EEOC, HUD, the New York State Division of Human Rights, the New York State Department of Labor, and the New York State Department of Environmental Conservation, and since 2015 has been retained for investigations by the New York State Office of the Attorney General for public entities and private businesses.

SESSION 1 – Negotiating the Monell 30(b)(6) Notice After the Consent Decrees End | 12:00pm – 1:00pm

This session examines how municipal defense attorneys should negotiate, narrow, and respond to Rule 30(b)(6) deposition notices in §1983 Monell cases against the backdrop of the 2025 federal consent decree withdrawals. Attorneys will learn how the end of DOJ oversight reshapes the topics plaintiffs’ counsel will notice, what doctrinal and evidentiary tools are available to limit institutional testimony, and how to use the 2020 Rule 30(b)(6) amendment’s conferral requirement as a structured defense mechanism. Participants will leave with concrete strategies for objecting to overbroad topics, invoking proportionality, and insulating the deposition record from the most dangerous consent decree rollback theories.

BREAK | 1:00pm – 1:10pm

SESSION 2 – Preparing the Municipal Designee and Controlling the Deposition Record | 1:10pm – 2:10pm

This session addresses the selection, preparation, and in-deposition management of the municipal 30(b)(6) designee in Monell litigation. Attorneys will learn how designee testimony functions as a party admission, how to structure preparation to satisfy the Rule 30(b)(6) obligation while minimizing binding concessions, and how to control the deposition record in real time. Attendees will leave with a framework for designee selection, a preparation protocol keyed to Monell’s four liability pathways, and concrete techniques for managing scope, contention questions, and post-deposition damage control.