Eaton Corp. v. Votour

Eaton Corporation and GAB Robins North America, Inc., employer and carrier (E/C), appeal the judge of compensation claims’ (JCC) order awarding appellee Dottie Votour (claimant) certain disability benefits. They argue the JCC erred in excluding surveillance videos taken of claimant’s activities from admission as impeachment evidence, as authorized by Florida Administrative Code Rule 60Q-6.113(2), which requires a party to inform the opposing party before the final hearing of any evidence that will be used, except for impeachment evidence. Because we conclude the JCC abused her discretion in…