The more charitable read is that this is a "my dog ate my homework" excuse to not attend deposition.
Two years ago he wanted his factories to continue producing cars and didn't see the virus as good enough reason to stop, now he seems it see it as enough of a reason to not appear on a disposition, after apparently having been infected twice already.
You can also constantly find pictures and videos of him being around people etc. Musk said that the interviewing attorney had contact with an infected person 4 days prior. Yet, this attorney tested negative multiple times.
So why is a disposition suddenly an issue?
Probably because he doesn't want to attend it, or rather, wants as much time as possible to prepare with his lawyers.
That's just my speculation, of course.
He's trying to play "gotcha". Either they do care about COVID and grant his request or they've been lying the whole time about COVID.
But that's a false dichotomy. He's betting on the court not saying "You're being disingenuous about your concerns" or "Our protocols for COVID have changed due to X, Y, and Z, so there are no more exceptions".
He believes he can play semantic games to get out of doing things. Because that's worked for him in the past. But the only reason that worked for him in the past is because of money. The people he used it on had no recourse against his resources. He's running into the hard wall of reality most of us run into a long time ago. He's finally up against someone who has even more resources than he does.