State Ex Rel. Missouri Pacific Railroad v. Koehr

HOLSTEIN, Judge.

“One •picture is worth more than 10,000 words.”

Chinese Proverb

The issue presented in this case is whether surveillance photographs or motion pictures are, as suggested by the adage, a “statement” of a party discoverable under Rule 56.01(b)(3). This Court concludes that such surveillance materials are discoverable under the rule.

In the underlying case John D. Brown, an engineer for defendants, seeks recovery for various injuries allegedly caused by defendants, relators in this proceeding. Plaintiff, in a request for production, sought:

All photographs or motion pictures taken of…