Barbuto v. Ronquillo-Horton, 1:22-cv-00569

Plaintiff Anthony Settimo Barbuto (through his guardian Patricia Ann McCarthy) claims his rights were violated by Dr. Karen Ronquillo-Horton when denied appropriate medical care while incarcerated in June 2019.
The trial was scheduled for October 7, 2024, over a year in advance.
Dr. Ronquillo-Horton, the sole defendant, took a new job in the UK and cited an inability to attend trial due to a 90-day probationary period tied to her employment.
Defendant moved to adjourn trial or, alternatively, to allow remote testimony via video conference.
Plaintiff opposed both requests, arguing delay and remote testimony would prejudice his ability to present his case and challenge defendant's credibility.
Court was asked to decide the motion one day before the final pretrial conference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adjournment of Trial	Delay would prejudice plaintiff; trial long scheduled, witness availability uncertain	Needs delay due to UK job and inability to travel during probation	Denied; no extraordinary circumstances, fairness to plaintiff precludes postponement
Permission for Remote Testimony	Defendant's credibility is central; remote testimony would impair cross and jury assessment	Inability to leave UK job; employer willing to allow remote testimony as alternative	Denied; no compelling circumstances, live testimony essential for credibility

Thornton v. Snyder, 428 F.3d 690 (7th Cir. 2005) (Noting limitations of videoconference proceedings in evaluating witness credibility)
United States v. Lawrence, 248 F.3d 300 (4th Cir. 2001) (Virtual proceedings are not equivalent to physical presence at trial)