Lindsey v. County of Erie
The plaintiff, Ms. Lindsey, an employee of Ciminelli Construction Company, was injured at a worksite on March 21, 2000, and subsequently sought both Labor Law benefits and workers' compensation. After workers' compensation benefits were suspended due to alleged misrepresentation, Ms. Lindsey filed a motion seeking to compel Travelers Insurance Company, the compensation carrier, to produce surveillance videotapes prior to further Workers' Compensation Board proceedings. Travelers Insurance Company argued that such discovery would violate administrative rules; however, the court found that CPLR 3101 (i) was controlling in the civil action. The court further determined that Travelers, despite not being a direct party to the Labor Law action, created the surveillance tapes for its overall defense of claims against its insured, making them discoverable. Consequently, the court granted the plaintiff's motion, ordering Travelers Insurance Company to immediately deliver all surveillance tapes to the plaintiff's counsel.