Automated Summary
Key Facts
On April 25, 2019, in Key Largo, Florida, a 2019 Tesla Model S equipped with Autopilot collided with a parked Chevrolet Tahoe, which then struck Naibel Benavides Leon (deceased) and Dillon Angulo. The plaintiffs, representing the estate of Benavides Leon and Angulo, sued Tesla. Following a trial on July 14, 2025, Tesla moved to compel disclosure of PowerPoint slides used during trial. The court granted the motion, ordering parties to exchange copies of their respective trial slides by December 29, 2025.
Deceased Name
Naibel Benavides Leon
Issues
The court addressed whether Tesla's motion to compel disclosure of plaintiffs' opening and closing PowerPoint slides used during trial should be granted. The court considered Federal Rule of Evidence 107 regarding illustrative aids and whether the slides should be incorporated into the record for appeal purposes. The court determined that PowerPoint slides constitute illustrative aids that must be entered into the record when practicable, and ordered the parties to exchange copies by December 29, 2025.
Date of Death
2019 April 25
Holdings
The Court granted Tesla Inc.'s Motion to Compel Plaintiffs to Provide Copies of Opening and Closing PowerPoint Slides, ordering that the parties exchange copies of their respective PowerPoint slides used during trial no later than December 29, 2025. The Court found that the slides should be disclosed because Rule 107 of the Federal Rules of Evidence requires illustrative aids used at trial to be entered into the record when practicable.
Remedies
The Court granted Tesla Inc.'s motion to compel Plaintiffs to provide copies of opening and closing PowerPoint slides used during trial, ordering the parties to exchange these slides by December 29, 2025, to ensure a complete record for appeal purposes.
Legal Principles
Rule 107 of the Federal Rules of Evidence provides that although an illustrative aid is not evidence, when practicable, an illustrative aid used at trial must be entered into the record. The Eleventh Circuit has concluded that PowerPoint slides constitute illustrative aids, and they should only be kept out of the record if their inclusion would be impracticable.
Precedent Name
Sanchez v. Discount Rock & Sand, Inc.
Cited Statute
Federal Rules of Evidence
Judge Name
Judge Beth Bloom
Passage Text
- Accordingly, it is ORDERED AND ADJUDGED that Tesla's Motion, ECF No. [556], is GRANTED. The parties shall exchange copies of their respective PowerPoint slides used during trial no later than December 29, 2025.
- The Court agrees with Tesla that the PowerPoint slides the parties utilized at trial should be disclosed and ultimately incorporated into the record. As Tesla correctly points out, Rule 107 of the Federal Rules of Evidence provides that, although '[a]n illustrative aid is not evidence, [w]hen practicable, an illustrative aid used at trial must be entered into the record.' Fed. R. Evid. 107 (emphasis added). The Eleventh Circuit has concluded that PowerPoint slides constitute illustrative aids.
- Plaintiffs have offered no suggestion that disclosure to opposing counsel or incorporation of the slides into the record would be impracticable. Therefore, the Court finds that disclosure of the PowerPoint slides to Tesla is appropriate.