Holbourn v. NCL (Bahamas) Ltd.

305 F.R.D. 685, 2014 U.S. Dist. LEXIS 183589, 2014 WL 8630709
CourtDistrict Court, S.D. Florida
DecidedSeptember 26, 2014
DocketCase No. 14-21887-CIV
StatusPublished
Cited by6 cases

This text of 305 F.R.D. 685 (Holbourn v. NCL (Bahamas) Ltd.) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Holbourn v. NCL (Bahamas) Ltd., 305 F.R.D. 685, 2014 U.S. Dist. LEXIS 183589, 2014 WL 8630709 (S.D. Fla. 2014).

Opinion

ORDER DENYING DEFENDANT’S MOTION FOR PROTECTIVE ORDER

ALICIA M. OTAZO-REYES, United States Magistrate Judge.

THIS CAUSE came before the Court upon Defendant NCL (BAHAMAS) LTD.’s (“NCL” or “Defendant”) Motion for Protective Order Regarding Production of CCTV Video (hereafter “Motion for Protective Order”) [D.E. 23], This matter was referred to the undersigned pursuant to 28 U.S.C. § 636 by the Honorable Ursula Ungaro, United States District Judge [D.E. 24], The undersigned held a hearing on this matter on September 10, 2014. For the reasons stated below, the undersigned denies the Motion for Protective Order.

FACTUAL BACKGROUND

Plaintiff Jennifer Holbourn (“Holbourn” or “Plaintiff’) brings this action against NCL as a result of injuries she alleges to have sustained while a passenger aboard NCL’s cruise ship Norwegian Breakaway. In her hand-written statement given shortly after the incident, Holbourn states: “Walking on deck 16; sun lounger blew across deck striking my legs and knocking me down onto my right hip/shoulder.” See Passenger Statement Form [D.E. 28-2], In her Complaint, Holbourn further alleges that on the day of the incident “the weather had been cloudy, rainy, and windy all day. Yet, the crew of the ship left the lounge chairs in their open positions and placed on the deck so that they were on the open part of the deck subject to the high winds.” See Complaint [D.E. 1 at ¶11].

NCL captured the incident described by Holbourn on three different closed-circuit television cameras (hereafter, “Videos”). NCL claims that the Videos, which are covered by Holbourn’s requests for production, are protected by the work product privilege. Notwithstanding its privilege claim, NCL is willing to produce the Videos after Holb-ourn’s deposition. NCL objects to production of the Videos prior to Holbourn’s deposi[687]*687tion on the grounds that such production “will severely prejudice the Defendant’s ability to obtain the Plaintiff [sic] unrefreshed recollection of events. If the Plaintiff is allowed to view the video footage the Plaintiff will be able to tailor her recollection of events and testimony to what is depicted on the video.” See Defendant’s Motion for Protective Order [D.E. 23 at ¶ 3]. Thus, the two issues presented in the Motion for Protective Order are: (1) whether the Videos are protected by the work product privilege; and (2) whether NCL should be required to produce the Videos prior to Holbourn’s deposition. As more fully discussed below, the undersigned finds that the Videos are not protected by the work product privilege, and that NCL has not carried the burden to justify delayed production of the Videos.

DISCUSSION

1. The Work Product Privilege Claim

“The attorney work product privilege generally protects documents prepared by an attorney in anticipation of litigation.” Miccosukee Tribe of Indians of Fla. v. U.S., 516 F.3d 1235, 1263 (11th Cir.2008) (citing Hickman v. Taylor, 329 U.S. 495, 509-10, 67 S.Ct. 385, 91 L.Ed. 451 (1947)). “[I]n order for the work product doctrine to apply, the party asserting the doctrine must demonstrate that at the time the materials were created or drafted, the entity must have anticipated litigation.” Schulte v. NCL (Bahamas) Ltd., No. 10-23265-CIV, 2011 WL 256542, at *2 (S.D.Fla. Jan. 25, 2011) (Simonton, Mag. J.) (citing CSX Transp. Inc. v. Admiral Ins. Co., No. 93-132-CIV-J-10, 1995 WL 855421, at *2 (M.D.Fla. July 20, 1995)). “Thus, materials or documents drafted or created in the ordinary course of business are not protected.” Id.

Here, the Videos were obtained from surveillance cameras, hence created in the ordinary course of business. Yet NCL claims that the Videos are protected by the work product privilege because “an act giving rise to the accrual of a claim against the Defendant occurred, namely, the Plaintiffs fall on board the Norwegian Breakaway. As accidents onboard cruise ships routinely lead to litigation, after the accident the video was reviewed and preserved.” See Defendant’s Reply in Support of Motion for Protective Order (hereafter, “Reply”) [D.E. 30 at 4]. This same contention was rejected in Schulte, where NCL claimed that a surveillance video of a slip and fall accident aboard NCL’s Norwegian Jewel was protected by the work product privilege because “it was preserved based upon instructions by Counsel for NCL.” Schulte, 2011 WL 256542, at *3. There, Magistrate Judge Simonton reasoned that

once NCL was aware that a claim might be made based upon the Plaintiffs slip and fall incident, NCL had a duty to preserve that tape, and counsel had a duty to advise NCL to do so. In this regard, NCL’s decision to preserve the video is best viewed in the context of those cases where courts have examined spoliation claims based upon an entity’s failure to preserve evidence despite notice that [] a lawsuit might be forthcoming. It would be anomalous, to say the least, if by ordering a client to preserve evidence created in the ordinary course of business, in anticipation of litigation, counsel was able to shield that evidence from production based upon work product protection.

Id. (citations omitted).

In this case, as in Schulte, NCL relies on Bolitho v. Home Depot USA, Inc., No. 10-60053-Civ, 2010 WL 2639639 (S.D.Fla. June 3, 2010) (Seltzer, Mag. J.) for the proposition that the Videos are entitled to work product protection. See Reply [D.E. 30 at 4], As noted in Schulte, however, the Bolitho decision relied on a case involving “a request for a surveillance video made after the incident, rather than a video of the actual accident made prior to the anticipation of litigation.” Schulte, 2011 WL 256542, at *4. Thus, Magistrate Judge Simonton “deeline[d] to follow Bolitho to the extent that it holds that a surveillance video made in the regular course of an entity’s business, which captures an accident at the time it occurs, becomes work product when counsel orders its preservation.” Id. The undersigned agrees with the analysis and conclusions in Schulte and finds [688]*688that the Videos are not protected by the work product privilege.1

2. The Request to Delay Production of the Video

As previously noted, notwithstanding its privilege claim, NCL is willing to produce the Videos after Holbourn’s deposition. According to NCL, pre-deposition production of the Videos is prejudicial because it presents the risk that Holbourn will tailor her testimony to what is depicted in them. NCL relies for its request on Fed.R.Civ.P. 26(d), which provides, in pertinent part:

(d) Timing and Sequence of Discovery.
(2) Sequence. Unless, on motion, the court orders otherwise for the parties’ and witnesses’ convenience and in the interests of justice:
(A) methods of discovery may be used in any sequence; and

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Huskey v. CFJ Properties
S.D. Florida, 2025
Willard v. Richardson
M.D. Florida, 2024
Avila v. Target Corporation
E.D. New York, 2021
Goosby v. Branch Banking & Trust Co.
309 F. Supp. 3d 1223 (S.D. Florida, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
305 F.R.D. 685, 2014 U.S. Dist. LEXIS 183589, 2014 WL 8630709, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holbourn-v-ncl-bahamas-ltd-flsd-2014.