Short answer. Yes, if he held the right position when the deposition was taken. The rule lets an adverse party use, for any purpose, the deposition of an officer, director or managing agent of a corporation, partnership or association that is a party to the case.
What the law says
(b) The deposition of a party or of any one who at the time of taking the deposition was an officer, director, or managing agent of a public or private corporation, partnership, or association which is a party may be used by an adverse party for any purpose
Rule 23, Section 4 — Use of depositions. Read the full provision →
For any purpose means as substantive evidence
Most depositions may be used only to impeach, or in place of a witness who cannot be produced. This paragraph is different. Where the deponent is a party, or was an officer, director, or managing agent of a corporation, partnership or association that is a party, the deposition may be used by an adverse party for any purpose. That includes proving the facts stated in it, whether or not the deponent appears and testifies.
The status is fixed at the time of the deposition
The wording is precise about timing: the person must have held one of those positions at the time of taking the deposition. A resignation, retirement or dismissal afterwards does not undo the use the rule permits. Conversely, someone who was an ordinary employee when deposed and became an officer later does not fall within this paragraph, however senior they are by the time of trial.
Only an adverse party may use it this way
The privilege runs one way. The paragraph gives this latitude to an adverse party, which prevents an organisation from generating favourable evidence by deposing its own officers and then offering the transcript instead of producing them. If you are on the other side of that transcript, the practical response is usually to call the officer live, so that the deposition is met by testimony rather than standing alone.
Who is a managing agent, and the conditions that still apply
The three named roles are not identical, and managing agent is the one most often contested — it describes responsibility and authority rather than a job title, so expect the point to be tested if the officer's role was modest. The general conditions also remain: the deposition is usable only so far as admissible under the rules of evidence, and only against a party present or represented at its taking or who had due notice of it.
What the paragraph does not give you
For any purpose describes the uses to which the deposition may be put; it is not an exemption from the rules of evidence. Hearsay within the deposition remains hearsay, an opinion the deponent was not competent to give remains inadmissible, and privilege is not waived by the transcript's existence. The paragraph also does not compel the court to prefer the deposition over live testimony that contradicts it. And it says nothing about depositions of ordinary employees, however well informed — those fall back on the general conditions, including unavailability.