Dinsmore Steele v. Anderson
- Figueredo
- 1:26-cv-00582
- U.S. District Court · Southern District of New York
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Dinsmore Steele v. Anderson, Judge Figueredo ordered Plaintiff’s CEO’s Rule 30(b)(6) deposition to occur in person in Manhattan.
Dinsmore Steele, LLC’s CEO, Plaintiff’s counsel, and Defendants’ counsel are affected by the order governing the deposition’s format and location.
What happened
Dinsmore Steele, LLC sued Cassandra Anderson and others in the Southern District of New York. During a conference, the parties disputed whether Plaintiff’s CEO, who would testify as Plaintiff’s designated representative, had to appear for a deposition in person or could testify remotely.
Defense counsel requested an in-person deposition in Manhattan. Plaintiff’s counsel requested a remote deposition. The opinion states that the CEO lives on Long Island and has an office in Manhattan, and that Plaintiff filed the case in that federal district.
Judge Valerie Figueredo ordered the deposition to take place in person in Manhattan. She concluded that requiring the CEO to travel there would not impose a hardship, while Plaintiff’s Chicago-based counsel could participate remotely.
The detailed version
- Dinsmore Steele v. Anderson · No. 1:26-cv-00582
- Figueredo
- Aug. 20, 2026
Background
At an August 19, 2026 conference, defense counsel raised a dispute over the format and location of the deposition of Plaintiff’s CEO. The CEO was to testify as Plaintiff’s Rule 30(b)(6) designee. Under Rule 30(b)(6), an organization designates a person to testify on its behalf about information known or reasonably available to the organization.
Defense counsel sought an in-person deposition in Manhattan. Plaintiff’s counsel asked the Court to order a remote deposition. The opinion states that whether to allow a remote deposition is within the Court’s discretion. It also notes the general rule that a plaintiff who chooses the forum for a lawsuit must generally make the relevant person available for examination there.
Court’s Analysis
The Court noted that Plaintiff’s CEO resides on Long Island and has an office in Manhattan. Plaintiff also filed the lawsuit in the Southern District of New York. Based on those facts, the Court determined that requiring the CEO to travel to Manhattan for the deposition would not impose a hardship. The Court further noted that Plaintiff’s counsel, who is in Chicago, could participate remotely.
Order
The Court ordered that Plaintiff’s CEO’s deposition occur in person in Manhattan. The order does not expressly describe the result as granting or denying a motion; it states the required deposition arrangement and concludes, “SO ORDERED.”
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.