On October 26, 2020 a
Stipulation,Agreement
was filed
involving a dispute between
Forbes, Keith,
and
Heritage Property & Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Filing # 126569904 E-Filed 05/11/2021 12:39:45 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE20017837, DIVISION 14 JUDGE Carlos A Rodriguez
Keith Forbes
Plaintiff(s) / Petitioner(s)
Vv.
Heritage Property & Casualty Insurance Company
Defendant(s) / Respondent(s)
/
AGREED ORDER ON DEFENDANT’S MOTION FOR PROTECTIVE ORDER AS
TO PLAINTIFF’S DEPOSITION OF DEFENDANT’S DESIGNATED CORPORATE
REPRESENTATIVE
THIS CAUSE having come before the Court regarding Defendant’s Motion for Protective
Order as Plaintiff's Deposition of Defendant's Designated Corporate Representative, and the
Court being otherwise duly advised in the premises, it is hereupon:
ORDERED AND ADJUDGED that:
Defendant’s Motion for Protective Order is GRANTED and Defendant's Objections are
SUSTAINED. The Corporate Representative may bring the Defendant’s claims file that is
responsive to the duces tecum to the deposition for purposes of refreshing the Corporate
Representative’s recollection. However, neither the Corporate Representative nor the
Defendant will produce any documents other than what was previously produced to Plaintiffs
by Defendant in response to the duces tecum. Neither party is waiving any objection nor any
privilege including those previously asserted or asserted for the first time at the deposition.
Use of privileged claim file materials to prepare for the deposition and/or refresh recollection
during the deposition will not constitute waiver of any privilege and/or subject the materials to
production. Defendant’s witness shall not testify about general claim handling, general claim
administration, policy interpretation and/or any information protected from disclosure by the
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/11/2021 12:39:44 PM.****CaseNo: CACE20017837
Page 2 of 2
attorney/client privilege, if any, and/or work product doctrine. Plaintiff has the right to have
Defendant's objections reconsidered by the Court, should Plaintiffs believe a legal justification
to do so arises.
DONE and ORDERED in Chambers, at Broward County, Florida on 05-11-2021.
<6 GirotsghCsls-goor-r9:53 sm
CACE20017837 05-11-2021 10:33 AM
Hon. Carlos A Rodriguez
CIRCUIT JUDGE
Electronically Signed by Carlos A Rodriguez
Copies Furnished To:
Aaron D. Silvers , E-mail : DAR@WEKlaw.com
Aaron D. Silvers , E-mail : AS@WEKlaw.com
Aaron David Silvers , E-mail : dadams@schillingsilvers.com
Aaron David Silvers , E-mail : asilvers@schillingsilvers.com
Aaron David Silvers , E-mail : dariste@schillingsilvers.com
Kevin Weisser , E-mail : as@weklaw.com
Kevin Weisser , E-mail : dar@weklaw.com
Precious Monae-Anuel Lawrence , E-mail : scrisafulli@heritagepci.com
Precious Monae-Anuel Lawrence , E-mail : msanchez@heritagepci.com
Precious Monae-Anuel Lawrence , E-mail : plawrence@heritagepci.com
Sapir Elazar , E-mail : SE@WEKLaw.com
Sapir Elazar , E-mail : JM@WEKLaw.com
Sapir Elazar , E-mail : AB@WEKLaw.com
Document Filed Date
May 11, 2021
Case Filing Date
October 26, 2020
Category
Contract and Indebtedness
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Filing # 126569904 E-Filed 05/11/2021 12:39:45 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE20017837, DIVISION 14 JUDGE Carlos A Rodriguez Keith Forbes Plaintiff(s) / Petitioner(s) Vv. Heritage Property & Casualty Insurance Company Defendant(s) / Respondent(s) / AGREED ORDER ON DEFENDANT’S MOTION FOR PROTECTIVE ORDER AS TO PLAINTIFF’S DEPOSITION OF DEFENDANT’S DESIGNATED CORPORATE REPRESENTATIVE THIS CAUSE having come before the Court regarding Defendant’s Motion for Protective Order as Plaintiff's Deposition of Defendant's Designated Corporate Representative, and the Court being otherwise duly advised in the premises, it is hereupon: ORDERED AND ADJUDGED that: Defendant’s Motion for Protective Order is GRANTED and Defendant's Objections are SUSTAINED. The Corporate Representative may bring the Defendant’s claims file that is responsive to the duces tecum to the deposition for purposes of refreshing the Corporate Representative’s recollection. However, neither the Corporate Representative nor the Defendant will produce any documents other than what was previously produced to Plaintiffs by Defendant in response to the duces tecum. Neither party is waiving any objection nor any privilege including those previously asserted or asserted for the first time at the deposition. Use of privileged claim file materials to prepare for the deposition and/or refresh recollection during the deposition will not constitute waiver of any privilege and/or subject the materials to production. Defendant’s witness shall not testify about general claim handling, general claim administration, policy interpretation and/or any information protected from disclosure by the *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/11/2021 12:39:44 PM.****CaseNo: CACE20017837 Page 2 of 2 attorney/client privilege, if any, and/or work product doctrine. Plaintiff has the right to have Defendant's objections reconsidered by the Court, should Plaintiffs believe a legal justification to do so arises. DONE and ORDERED in Chambers, at Broward County, Florida on 05-11-2021. <6 GirotsghCsls-goor-r9:53 sm CACE20017837 05-11-2021 10:33 AM Hon. Carlos A Rodriguez CIRCUIT JUDGE Electronically Signed by Carlos A Rodriguez Copies Furnished To: Aaron D. Silvers , E-mail : DAR@WEKlaw.com Aaron D. Silvers , E-mail : AS@WEKlaw.com Aaron David Silvers , E-mail : dadams@schillingsilvers.com Aaron David Silvers , E-mail : asilvers@schillingsilvers.com Aaron David Silvers , E-mail : dariste@schillingsilvers.com Kevin Weisser , E-mail : as@weklaw.com Kevin Weisser , E-mail : dar@weklaw.com Precious Monae-Anuel Lawrence , E-mail : scrisafulli@heritagepci.com Precious Monae-Anuel Lawrence , E-mail : msanchez@heritagepci.com Precious Monae-Anuel Lawrence , E-mail : plawrence@heritagepci.com Sapir Elazar , E-mail : SE@WEKLaw.com Sapir Elazar , E-mail : JM@WEKLaw.com Sapir Elazar , E-mail : AB@WEKLaw.com