West Plam Beach accidetn vicitm discovery requests regarding Surveillance Call 1-800-74-TRIAL

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 West Palm Beach Car Accident Plaintiff, the precise dates and times of the surveillance, and any information obtained from the surveillance.
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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 West Palm Beach Car Accident Plaintiff.
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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 West Palm Beach Car Accident Plaintiff, West Palm Beach Car Accident Plaintiff’s family, friends, neighbors, co-workers, acquaintances, or otherwise, concerning West Palm Beach Car Accident Plaintiff’s injuries, damages, restrictions, activities, etc.
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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 West Palm Beach Car Accident Plaintiff, West Palm Beach Car Accident Plaintiff’s family, friends, neighbors, co-workers, acquaintances, or otherwise, concerning West Palm Beach Car Accident 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 West Palm Beach Car Accident Plaintiff’s family, friends, neighbors, acquaintances, or otherwise.
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5. 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 defendants, its insurance company, or attorney or otherwise who performed any investigation, interviews, surveillance, conversations, formal or informal, recorded or unrecorded, etc. of West Palm Beach Car Accident Plaintiff, West Palm Beach Car Accident Plaintiff’s family, friends, neighbors, co-workers, acquaintances, or otherwise, concerning West Palm Beach Car Accident Plaintiff’s injuries, damages, restrictions, activities, etc.
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6. Please provide all unedited video or audio recordings created or prepared by any individual, agent, servant, employee, representative, private investigator, etc., of the defendants, its insurance company, or attorney or otherwise who performed any investigation, interviews, surveillance, conversations, formal or informal, recorded or unrecorded, etc. of West Palm Beach Car Accident Plaintiff, West Palm Beach Car Accident Plaintiff’s family, friends, neighbors, co-workers, acquaintances, or otherwise, concerning West Palm Beach Car Accident Plaintiff’s injuries, damages, restrictions, activities, etc.
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