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Remote Possibilities: Establishing Good Cause for Virtual Depositions in the Commercial Division

Under Rule 37 of the Rules of the Commercial Division, the court may order a remote deposition upon (1) consent of the parties, or upon (2) a motion showing good cause....more

Obtaining Discovery Across International Borders: Convenience Is Not the Standard

Sections 3102 and 3108 of the CPLR outline methods for conducting discovery, including discovery “outside” or “without” the state.  But what about demands for discovery and inspection of documents located outside the country?...more

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