Health concerns over the lingering COVID-19 pandemic have given life to Rule 30(b)(4) of the Federal Rules of Civil Procedure, which provides: “The parties may stipulate—or the court may on motion order—that a deposition be taken by telephone or other remote means.” Trial courts in the Second Circuit are encouraging parties to stipulate to remote depositions to minimize the risks of COVID-19 exposure, with some courts ordering remote depositions as the default in pending cases.
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