The City of Port St. Lucie v. Vallerie Follano

Petitioner, the City of Port St. Lucie, seeks certiorari review of an order compelling production of certain photographs, which it claims are protected work product. The trial court found the photographs discoverable under Florida Rule of Civil Procedure 1.280(b)(4) but failed to conduct an in camera review before making that determination. We therefore grant the City’s petition, quash the trial court’s order, and remand for an in camera review and an evidentiary hearing.

Respondent, Vallerie Follano, sued the City for negligence after stepping into an uncovered sewer valve access pipe up to…