In Grossman v. Emergency Cesspool and Sewer Cleaners (162 Misc. 2d 440 [Sup Ct, Queens County 1994]) plaintiff demanded production of "all surveillance reports, correspondence, memoranda, bills, invoices and proof of payments for surveillance, investigative services reported, records, notes and logs of all of the parties and any material relevant to this lawsuit that the defendant(s) intends to produce at the time of the trial, and the names and addresses of all investigators and photographers in this matter. This includes, but is not limited to records of amount of footage of film/video/audio tape used; the type of equipment used to take, develop and convert/edit and transfer and transcribe such film/tape; the make and model of all equipment, lenses and range settings used". The court denied disclosure of these materials stating that "CPLR 3101 (i) does not either expressly or impliedly refer to any of the above information demanded such as invoices, reports, correspondence, bills, records of footage, proof of payment, logs of surveillance, etc." (Id. at 443.) The court further held they were not discoverable absent a showing of substantial need and undue hardship (id.).