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Discovery rules." one court declared, " ; . [t]he surprise which results from distortion of misidentification is plainly unfair. if it is unleashed at the time of trial, the opportunity for an adversary to protect against its damaging inference by attacking the integrity of the film and developing counter-evidence is gone or at least greatly diminished." jenkins v. rainner, 350 a.2d 473, 477 n.j. 1976 ; . courts also have recognized the potential for abuse in the creation and use of surveillance materials. this potential for misuse has best been explained by the court in snead v. american export-isbrandtsen lines, inc., 59 f.r.d. 148, 150 e.d. pa. 1973 ; in the passage cited in judge johnson' opinion and quoted above. see also, s dimichel v. south buffalo ry. co., 604 n.e.2d 63, 68 n.y. 1992 ; , cert. denied 114 s. ct. 68 1993 ; "because films are so easily altered, there is a very real danger that deceptive tapes, inadequately authenticated, could contaminate the trial process surveillance films are extraordinarily susceptible to manipulation, and, once altered, are peculiarly dangerous." jenkins v. rainner, 350 a.2d 473, 477 n.j. ; ; 1976 ; surveillance films ; ; olszewski v. howell, 253 a.2d 77, 78 del. super. ct. 1969 ; surveillance film ; . only by acquiring these materials can the plaintiff establish their accuracy and authenticity. plaintiff may also need to depose the individuals responsible for making the surveillance materials in order to aid in establishing their accuracy and authenticity, and to ascertain the circumstances surrounding their creation. courts have continually found these reasons to be sufficient to establish substantial need. see, suezaki v. superior court of santa clara county, 373 p.2d 432 cal. 7 and internet poker games.
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Exception: if two pair are with the straight, apply two pair rule.
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