On April 15, 2021 a
Party Discovery
was filed
involving a dispute between
Quang Vo,
and
Fednat Insurance Company,
for CONTRACT & DEBT
in the District Court of Palm Beach County.
Preview
Filing # 143774023 E-Filed 02/11/2022 02:02:11 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
QUANG VO, CASE NO.: 50-2021-CA-004846
Plaintiff,
v.
FEDNAT INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S PRIVILEGE LOG
COMES NOW, Defendant, FEDNAT INSURANCE COMPANY, (hereinafter
“FEDNAT” or “Defendant”), by and through undersigned counsel, hereby files this, its
privilege log in connection with its response to Plaintiff's Request for Produce and states
as follows:
1. Claims File — 323 pages including Diagrams, photographs, invoices, internal
notes, reports and communications by Defendant’s field and desk adjusters and
vendor correspondence. Work Product and claims documents and discoverable in
first party action.
2. Claims Adjuster Notes — 5 pages dated throughout claims handling. Work
Product and claims documents not discoverable in first party action.
3. Internal e-mails - 16 pages. Work Product and claim documents not
discoverable in first party action.
4. Underwriting file — 71 pages including Policy jacket, insurance application,
photographs, prior insurance documents, diagrams. Underwriting file is not
discoverable in first party action.
5. Vendor Checks — 2 page. Work Product and claim documents not discoverable
in first party action.
6. ISO Report — 2 pages. Work Product, claim documents, and investigative reports
are not discoverable in first party action.
7. Work Product — 109 pages — FedNat Insurance Company, Inc.’s records,
reports, and photos.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 02/11/2022 02:02:11 PM ***CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on February 11, 2022, a true and correct copy of the
foregoing was furnished to Katherine A. Krepfle, Esq., KS Law Group, PLLC., 947
Longdale Avenue, Longwood, FL 32750 at Eservice@KSLawGroup.net;
KKrepfle@KSLawGroup.net.
CARABOTTA | STEAKLEY, PLLC
By: /s/ Ellie S. Einhorn
Ellie S. Einhorn, Esq.
Florida Bar No.: 111466
Jill D. Carabotta, Esq.
Florida Bar No.: 192287
12000 Biscayne Blvd., Suite 703
Miami, Florida 33181
Office: 305-874-7337
Email: filings@cslawpartners.com
Email: ellie@cslawpartners.com
Document Filed Date
February 11, 2022
Case Filing Date
April 15, 2021
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Filing # 143774023 E-Filed 02/11/2022 02:02:11 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA QUANG VO, CASE NO.: 50-2021-CA-004846 Plaintiff, v. FEDNAT INSURANCE COMPANY, Defendant. / DEFENDANT’S PRIVILEGE LOG COMES NOW, Defendant, FEDNAT INSURANCE COMPANY, (hereinafter “FEDNAT” or “Defendant”), by and through undersigned counsel, hereby files this, its privilege log in connection with its response to Plaintiff's Request for Produce and states as follows: 1. Claims File — 323 pages including Diagrams, photographs, invoices, internal notes, reports and communications by Defendant’s field and desk adjusters and vendor correspondence. Work Product and claims documents and discoverable in first party action. 2. Claims Adjuster Notes — 5 pages dated throughout claims handling. Work Product and claims documents not discoverable in first party action. 3. Internal e-mails - 16 pages. Work Product and claim documents not discoverable in first party action. 4. Underwriting file — 71 pages including Policy jacket, insurance application, photographs, prior insurance documents, diagrams. Underwriting file is not discoverable in first party action. 5. Vendor Checks — 2 page. Work Product and claim documents not discoverable in first party action. 6. ISO Report — 2 pages. Work Product, claim documents, and investigative reports are not discoverable in first party action. 7. Work Product — 109 pages — FedNat Insurance Company, Inc.’s records, reports, and photos. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 02/11/2022 02:02:11 PM ***CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on February 11, 2022, a true and correct copy of the foregoing was furnished to Katherine A. Krepfle, Esq., KS Law Group, PLLC., 947 Longdale Avenue, Longwood, FL 32750 at Eservice@KSLawGroup.net; KKrepfle@KSLawGroup.net. CARABOTTA | STEAKLEY, PLLC By: /s/ Ellie S. Einhorn Ellie S. Einhorn, Esq. Florida Bar No.: 111466 Jill D. Carabotta, Esq. Florida Bar No.: 192287 12000 Biscayne Blvd., Suite 703 Miami, Florida 33181 Office: 305-874-7337 Email: filings@cslawpartners.com Email: ellie@cslawpartners.com