Snyder v. Lindblad Expeditions LLC

Summary

The United States District Court for the Western District of Washington denied Colby Snyder’s motion to conduct remote depositions using audio/video recording without a court reporter and to use the recording as the official record. The Court held that the proposed procedures were insufficiently specified and did not demonstrate compliance with the Federal Rules of Civil Procedure concerning deposition officers, oaths, and certification.

Holdings

1. The court denied Snyder's request because he did not identify a qualifying oath-administering officer, specify the recording and certification procedures, or demonstrate that the depositions would comply with Federal Rules of Civil Procedure 28, 30, and 30(f)(1).
2. Defendants' response was timely because it was filed on January 7, 2026, fifteen days after Snyder filed the motion on December 23, 2025.
3. The court would not consider Snyder's new request for court-authorized administration of the oath because issues raised for the first time in a reply brief are waived.

Questions Presented

1. Whether the court should permit remote depositions to proceed without a court reporter or other qualifying deposition officer, with an audio or audiovisual recording serving as the official record.
2. Whether the court should authorize waiver or party-agreement administration of the oath, or permit a neutral officer to administer the oath under Rule 28(a)(2).
3. Whether defendants' response to the motion was untimely and should be disregarded.
4. Whether Snyder could raise in his reply a new request for court-authorized administration of the oath.

Disposition

other