Plaintiff's Disc Reqs Regarding Surveillance

1. Please identify any individual, agent, servant, employee, representative, private investigator, etc., of the defendant, its insurance company, attorney or otherwise who performed any surveillance on plaintiff, the precise dates and times of the surveillance, and any information obtained from the surveillance.

   ANSWER:

2. Please produce any and all video recordings, audio tapes, photographs, statements, oral or written, recorded or unrecorded, and reports, memoranda and/or log notes made, created, or prepared by any individual, agent, servant, employee, representative, private investigator, etc., of the defendant, its insurance company, or attorney or otherwise who performed any surveillance on plaintiff.

   ANSWER:

3. Please identify any individual, agent, servant, employee, representative, private investigator, etc., of the defendant, its insurance company, attorney, or otherwise who performed or undertook any investigation, interviews, surveillance, conversations, formal or informal, by telephone, e-mail, in person or otherwise, recorded or unrecorded, etc. of plaintiff, plaintiff’s family, friends, neighbors, co-workers, acquaintances, or otherwise, concerning plaintiff’s injuries, damages, restrictions, activities, etc.

   ANSWER:

4. Please identify the precise dates and times of any investigation, interviews, surveillance, conversations, formal or informal, recorded or unrecorded, by telephone, e-mail, in person or otherwise, of plaintiff, plaintiff’s family, friends, neighbors, co-workers, acquaintances, or otherwise, concerning plaintiff’s injuries, damages, restrictions, activities, etc. and the information obtained from the investigation, interviews, surveillance, conversations, formal or informal, recorded or unrecorded, etc. of plaintiff’s...