Seaboard Marine Ltd. v. Clark

Petitioner Seaboard Marine Ltd., the defendant below, seeks certiorari review of an order of the trial court compelling Seaboard to disclose to Respondent Farconelly Clark, the plaintiff below, certain work-product photographs that were developed by Seaboard’s attorneys. We grant certio-rari relief, and quash the trial court’s order, because Clark failed to exercise the due diligence required as a prerequisite for obtaining materials protected by Florida’s work-product privilege.

I. Facts

In February of 2012, Clark, an employee of a stevedoring company, was injured while working at Seaboard’s…