Yu Hui Chen v Chen Li Zhi, 2011 NY Slip Op 01267 (2d Dept. 2011)
“Here, the Supreme Court improvidently exercised its discretion in denying the plaintiff’s cross motion for a protective order pursuant to CPLR 3103(a) directing that his deposition be conducted by remote electronic means. The plaintiff demonstrated that traveling from China to the United States for his deposition would cause undue hardship”