Attached is a Memorandum of Law that I recently submitted in a slip and fall case in an attempt to secure the security video evidence of the fall before my client’s deposition.  The defense argued that it should not be produced prior to the plaintiff’s deposition because of its impeachment value.  The court focused on the word “solely” in Rule 26 and ordered the production before the plaintiff’s deposition.   UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA   JAMIE E. MASSUNG, Plaintiff, vs. DOLGENCORP, LLC t/d/b/a DOLLAR GENERAL and DOLLAR GENERAL, Defendants. CASE NO. 2:19-CV-01081-PLD PLAINTIFF’S MEMORANDUM IN SUPPORT OF PRODUCTION OF SECURITY ACCIDENT SCENE VIDEO WITHOUT DELAY Plaintiff