Gross v. Laver

56 Pa. D. & C.4th 134, 2002 Pa. Dist. & Cnty. Dec. LEXIS 227
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedFebruary 26, 2002
Docketno. 98-08236
StatusPublished

This text of 56 Pa. D. & C.4th 134 (Gross v. Laver) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gross v. Laver, 56 Pa. D. & C.4th 134, 2002 Pa. Dist. & Cnty. Dec. LEXIS 227 (Pa. Super. Ct. 2002).

Opinion

BRADLEY, J.,

Defendants, Arthur T. Laver M.D. and Pavilion Ob-Gyn Ltd., appeal from the entry of judgment in favor of plaintiffs, Lori L. and John K. Gross, husband and wife.

[136]*136This medical malpractice action arises out of the care rendered by Dr. Laver during surgery performed on Lori Gross. Dr. Laver, an obstetrician/gynecologist, was treating Lori Gross for infertility. At his recommendation, she underwent a diagnostic laparoscopy on June 5,1996, to rule out endometriosis as a cause of infertility. During the procedure, a sharp-pointed instrument, known as a trocar, was used by Dr. Laver to perforate the wall of plaintiff’s abdomen. It is through the trocar that the laparoscope can be inserted. After insertion of the trocar, Dr. Laver observed intra-peritoneal bleeding on Mrs. Gross’ left side from a venous source. Mrs. Gross’ left iliac vein had been lacerated by the trocar. Because the bleeding was uncontrolled, Dr. Laver performed an emergency laparatomy during which the bleeding point area was compressed until a vascular surgeon was available to repair the laceration. As a result of Dr. Laver’s alleged negligence, Mrs. Gross claims to have sustained injuries including neurological damage and deficit, disfigurement, continuing pain, disability and loss of income.

After numerous continuances at the parties’ requests, this matter was called for trial on June 25, 2001. After a three-day trial, the jury rendered a verdict in favor of Mrs. Gross in the amount of $1.2 million and in favor of Mr. Gross on his claim for loss of consortium in the amount of $100,000. Post-trial motions filed by the defendants were denied. Judgment was entered in favor of plaintiffs. This appeal followed.

The sole issue presented on this appeal is whether the trial court committed prejudicial error by precluding the defendants from presenting a surveillance videotape of Mrs. Gross.

[137]*137At trial, defendants sought to introduce into evidence a surveillance videotape of Lori Gross. It purportedly showed her engaging in activities which she had previously testified to having difficulty with in her deposition. Plaintiffs objected to admission of the surveillance tape on numerous grounds, including untimely production. Meanwhile defendants filed a motion in limine which sought to preclude an instructional videotape of a laparoscopy performed by plaintiff’s expert, Richard SoderstromM.D. Essentially, defendants objected to this videotape for the identical reasons that plaintiffs objected to admission of defendants’ surveillance tape. After pointing out the logical inconsistency of the parties’ positions, the court gave defendants a choice: Either both videotapes would be admitted or neither videotape would be admitted. Defendants chose the latter and now claim the trial court committed prejudicial error by precluding defendants from presenting the surveillance videotape of Mrs. Gross.1

“The admission of photographic or videotaped evidence is always within the sound discretion of the trial court and will not be reversed absent an abuse of that discretion.” Commonwealth v. Long, 425 Pa. Super. 170, 183-84, 624 A.2d 200, 207 (1993), alloc. denied, 535 Pa. 645, 633 A.2d 150 (1993). We believe the preclusion of the surveillance videotape was proper for the following reasons.

[138]*138First, defendants never forwarded in a timely manner, an unedited version of the surveillance videotape. Indeed, to date, defendants have never provided or offered to provide the unedited version of the entire surveillance videotape, the identity of the investigator who shot the videotape, the investigator’s contemporaneous notes, the time span of the videotape, or any other matter in the investigator’s report or file.

A review of the discovery history reveals that although information regarding surveillance videotapes was clearly sought by plaintiffs, none was forthcoming from defendants until approximately one month before trial. Plaintiffs’ interrogatory number thirty-four asked defendant to “[s]tate whether or not the defendant knows of the existence of any videotape, photograph, or any other recording made during, in relation to, or as a result of the treatment, surgery, or examination which is the subject matter of plaintiffs’ complaint. Plaintiffs’ Interrogatories Addressed to Defendants Arthur T. Laver M.D. and Pavilion Ob-Gyn Ltd., dated February 9,2000, exhibit A to plaintiffs’ memorandum of law in support of plaintiffs’ response to the motion for post-trial relief of defendants, Arthur T. Laver M.D. and Pavilion Ob-Gyn Ltd. On that same date, plaintiffs requested the production of “the entire contents of any investigation file or files of the defendants, defendants’ attorney or other representative concerning the subject matter of this action . . . , [a]ny and all accident or incident reports concerning this accident, incident or occurrence, including but not limited to, any submitted by plaintiff or filled out, prepared by or under the direction of any employees, agents, servants, contractors or independent contractors of the de[139]*139fendants, and [a]ny and all videotapes, photographs, x-ray films, motion picture, diagrams or drawings of any person, place or thing which is directly or indirectly related to the accident, incident or occurrence which is [sic] subject of the plaintiffs’ cause of action. ...” Plaintiffs’ request for production of documents addressed to defendants Arthur T. Laver M.D. and Pavilion Ob-Gyn Ltd., nos. 1,6 and 7, attached as exhibit B to plaintiffs’ memorandum of law in support of plaintiffs’ response to the motion for post-trial relief of defendants Arthur T. Laver M.D. and Pavilion Ob-Gyn Ltd.

No surveillance tapes or investigative materials were identified or produced in response to these discovery requests. Nor were any such materials disclosed in defendants’ pretrial memorandum filed on January 10,2001. (Trial was delayed until June 25, 2001, at the parties’ request.) Only on May 23,2001, did defendants forward to plaintiffs an edited version of a surveillance videotape purportedly taken of Lori Gross on April 16, 2001. Not until June 21,2001, only four days before commencement of the trial in this action, did defendants provide an amended pretrial statement which informed this court as well as plaintiffs of defendants’ intent to use the surveillance videotape at trial.

In Dominick v. Hanson, 753 A.2d 824 (Pa. Super. 2000), the Pennsylvania Superior Court held that surveillance films constitute work product and must be disclosed in response to discovery requests. Defendants neither timely answered the pertinent discovery nor supplemented timely the nondisclosure once the videotape was obtained in late April 2001. Pa.R.C.P. 212.2(a)(4) also requires a party to list the surveillance [140]*140tape as a potential trial exhibit. A mere four days before trial is when defendants amended their pretrial statement to list the surveillance videotape as a potential exhibit. This was obviously untimely considering that defendants failed to provide any investigative material identifying the individual who shot the videotape or any information identifying the surrounding circumstances under which the videotape was shot.

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Related

Dominick v. Hanson
753 A.2d 824 (Superior Court of Pennsylvania, 2000)
Commonwealth v. Long
624 A.2d 200 (Superior Court of Pennsylvania, 1993)
Bindschusz v. Phillips
771 A.2d 803 (Superior Court of Pennsylvania, 2001)

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Bluebook (online)
56 Pa. D. & C.4th 134, 2002 Pa. Dist. & Cnty. Dec. LEXIS 227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gross-v-laver-pactcompldelawa-2002.