Over the course of the past year, conducting depositions via video-conference (e.g. Zoom) has evolved from being a rarity to the norm, giving rise to the question, when will litigation return to “normal?” On May 11, a federal magistrate judge in California may have taken a step back towards “normal.” In Masimo Corp. v. Apple Inc., Case No. 20-cv-0048 (C.D. Cal. May 11, 2021), Judge Early ruled that if Apple was going to insist upon video-depositions, it needed to provide affidavits from each witness setting forth whether or not each witness had worked in the office or attended any in-person meetings in the last 30 days. The Court also asked whether each witness would be required to continue to work remotely for the next 60 days. The Court ruled that depositions must go forward in person unless each witness can satisfy all three conditions. Put simply, the Court held, if the witness is meeting with people in person for ordinary work purposes, then the witness can attend an in-person deposition.