QUESTION: When surveilling, can the investigator take a video of you or note what you do inside your own or a friend’s house? Do I need to keep the shades closed if I want privacy? Is there any place that is off limits? ANSWER: Generally, discovery may be obtained on any NONPRIVILEGED information “that is relevant to the subject matter involved … ” The information requested need not meet the relevancy test for admissibility at trial. It is discoverable if it either would be admissible evidence OR “appears reasonably calculated.