On December 13, 2017, Chesapeake Circuit Court ordered the out-of-state Defendant to appear for his deposition locally in Virginia, pursuant to Va. S. Ct. Rule 4:5(a). The case is Seimetz v. Beck, No. CL17000667-00.

To the same effect are the Orders in Harrell v. Butch, Inc., No. CL99-794 (Portsmouth Aug. 18, 2000); Emuze v. Madison Howard Williams, No. 35260 (Hampton Jan. 7, 1998); Loayza v. Luick, No. CL93-1162 (Virginia Beach Oct. 19, 1993); and Flax v. Ezzell, No. 93-392 (Virginia Beach Oct. 15, 1993). Courts also rely on Va. Code §8.01-420.4 as authority for compelling attendance at deposition in Virginia by a foreign resident.