Discovery Documents

Support for Motion to Compel – Production of Documents

Sabo v. Winn-Dixie – Order Motion to Compel Video Surveillance

PLAINTIFF’S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS

Plaintiff’s Response to Motion to Compel Facebook Records

Order to Compel Production of Security Videotape

Order on FRCP 412- Use of past Sexual behavior

Order – Motion to Compel and Protective Order – medical records, non party victims, pseudonym

Opinion and Order: Tompkins v. Detroit Metropolitan Airport d/b/a Wayne County Airport Authority; in slip-and-fall case; discovery overly broad; no rummaging without predicate showing; airline requested that customer sign authorizations to release records from plaintiff’s social networking website account; social networking website account was protected from discovery as irrelevant and overly broad; “[The] Defendant does not have a generalized right to rummage at will through information that Plaintiff has limited from public view. Rather, […] there must be a threshold showing that the requested information is reasonably calculated to lead to the discovery of admissible evidence. Otherwise, the Defendant would be allowed to engage in the proverbial fishing expedition, in the hope that there might be something of relevance in Plaintiff’s Facebook account.”

Notice of Taking Remote Videotape Deposition Duces Tecum

Notice of Deposition and Document Request

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