Seaboard Marine Ltd. v. Clark » The Florida E-Discovery Case Law Database » Levin College of Law » University of Florida

Seaboard Marine Ltd. v. Clark

Seaboard Marine Ltd. v. Clark

Case Date: 09/16/2015
Citation: Seaboard Marine Ltd. v. Clark, 174 So. 3d 626 (Fla. 3d DCA 2015)
Court Type: District Court of Appeal
Court: Fla. 3d DCA
Judge: Judge: Edwin A. Scales III
Rule(s): Fla. R. Civ. P. 1.280

Petitioner sought to quash the trial court’s order to compel the production of ninety-one post-accident photographs, alleging that they were protected by the work-product privilege.


The Court granted the petition. Plaintiff Clark could only obtain Petitioner’s work product on a showing of undue hardship. However, Plaintiff failed to depose anyone or obtain any other post-accident photographs on his own. Plaintiff did not do his due diligence in discovering relevant evidence himself and could therefore not show the undue hardship required to obtain Petitioner’s work product.

Relevant Documents:

(Access to the case is confidential so the Briefs are unavailable)


E-Discovery Issues: Motion to Compel, Production Request
E-discovery Tags: Attorney-Client, Privilege, Work Product
E-discovery subjects: Photographs, Surveillance Footage

Published: January 26th, 2018

Category: Uncategorized

Comments are closed.