Court granted protective order for insurance investigator's report where plaintiff failed to establish substantial need for the report or waiver based on the disclosure of photographs that were only an ancillary part of the report.

Treating physician's causation opinion, though not based on objective medical records, was not improperly speculative where the physician would be familiar with the potential complications of claimant's surgery and could conclude that her subsequent neck pain was a consequence of surgery to repair a work injury to her shoulder.

Service upon foreign corporation was ineffective where service upon its domestic subsidiary could not impute notice of the action and mailing service of process to the foreign corporation did not comply with the requirements of the Hague Convention.