Reis v. McKinsey & Company
- Laurel Beeler
- 3:25-cv-00393
- U.S. District Court · Northern District of California
- 5
Counsel of record per CourtListener. Firm names are approximate.
In L. Reis v. McKinsey & Company, Inc., United States, Judge Beeler denied a remote deposition request and set in-person options, locations, expenses, and deadline.
The order directly affects L. Reis and the defendant, by determining how and where L. Reis must appear for her deposition and who must pay specified travel expenses.
What happened
In L. Reis v. McKinsey & Company, Inc., United States, the plaintiff, who lives in Texas and cares for two young children, asked to give her deposition by videoconference. The defendant had scheduled an in-person deposition at its counsel’s San Francisco office and offered Texas locations if the plaintiff paid one examining attorney’s reasonable travel expenses.
The plaintiff argued that traveling to San Francisco would create substantial travel, lodging, childcare, and safety burdens, and that a remote deposition would still allow a complete examination. The defendant argued that her hardship showing was general and unsupported, and that an in-person deposition was needed to assess her credibility and examine documents.
Judge Beeler denied the request for a remote deposition. The plaintiff must appear in person either in San Francisco at her own expense or at the nearest of defense counsel’s offices in Dallas, Houston, or Austin while reimbursing one examining attorney’s reasonable travel expenses. She must choose an option and provide at least three proposed dates within seven days, and the deposition must be completed by October 30, 2026.
The detailed version
- Reis v. McKinsey & Company · No. 3:25-cv-00393
- Laurel Beeler
- Sept. 9, 2026
Background
This employment case presented a dispute about the location and method of the plaintiff’s deposition. The plaintiff lives in Texas and is the primary caregiver for children ages three years and twenty months. She said she had no childcare available for overnight travel and asked to be deposed remotely by videoconference.
The defendant noticed an in-person deposition for August 11, 2026, at its counsel’s San Francisco office. It later offered to conduct the deposition at one of its counsel’s offices in Dallas, Houston, or Austin if the plaintiff reimbursed counsel’s reasonable travel expenses. The plaintiff declined that proposal. The parties met and conferred but did not resolve the dispute.
Legal Standard
The court explained that Federal Rule of Civil Procedure 26(c) allows a court, for good cause, to set discovery terms, including the time, place, and allocation of expenses. Rule 30(b)(4) allows a court to order a deposition by telephone or other remote means. A plaintiff ordinarily must make herself available for a deposition in the district where she chose to sue. To avoid that requirement, the plaintiff had to show undue hardship or exceptional or compelling circumstances.
Analysis
The court held that the plaintiff had not met that burden. Her showing consisted of statements from counsel that she was the primary caregiver, lacked overnight childcare, and would incur travel, lodging, and childcare expenses. The court said those burdens were real but, without more, were ordinary consequences of litigating in a distant forum the plaintiff had chosen. The record also lacked a declaration, cost estimate, response to the defendant’s assertion that her spouse could provide childcare during a short absence, or explanation of why the proposed Texas alternative was unworkable.
The court recognized the plaintiff’s arguments that remote depositions are common, that the defendant’s concerns about evaluating demeanor and handling exhibits were general, and that the defendant’s notice contemplated videoconferencing and paperless exhibits. But the court said the plaintiff’s arguments were not evidence and that the defendant could presumptively depose her in person in the selected forum, particularly because her claims and credibility were central to the case.
Ruling and Required Arrangements
The court denied the plaintiff’s request to be deposed remotely. The plaintiff must appear in person and may choose either:
1. Defense counsel’s San Francisco office, at her own expense; or 2. Whichever of defense counsel’s Dallas, Houston, or Austin offices is nearest her home, while reimbursing the reasonable travel expenses of one examining attorney, including economy airfare, ground transportation, and reasonable lodging.
Any counsel may attend by videoconference regardless of the deposition location. Within seven days of the order, the plaintiff must serve her election and at least three proposed deposition dates. If she does not do so, the defendant may notice the deposition at defense counsel’s San Francisco office with at least fourteen days’ notice. The deposition must be completed by October 30, 2026. The parties may agree to a different arrangement, including a remote deposition, without another court order. The court stated that the order resolved ECF No. 47.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.