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
According to the Centers for Disease Control and Prevention, motorcycle helmets saved an estimate 1,859 lives in 2016. Helmet use reduces the risk of death by 37% and the risk of head injury by 69%. PennDot states that one out of every five motorcycle crashes result in head or neck injuries. In 2016, states without universal helmet laws, 60% of motorcyclists killed were not wearing helmets compared to 8% in states with universal helmet laws. Statistics do not lie. Always wear a helmet when you ride.