Order: Ellen Arenberg, et al Plaintiff vs. Auto Club Insurance Company of Florida Defendant

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                                Filing # 134228732 E-Filed 09/08/2021 06:48:39 PM
 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
 IN AND FOR BROWARD COUNTY, FLORIDA
 CASE NO.
 CACE20017316
 DIVISION Ql JUDGE Mily R Powell
 Ellen Arenberg, et al
 Plaintiff(s)/ Petitioner(s)
 V.
 Auto Club Insurance Company of Florida
 Defendant(s)/ Respondent(s)
 '
 AGREED ORDER ON DEFENDANT'S MOTION FOR PROTECTIVE ORDER AS
 TO THE PLAINTIFFS' NOTICE OF TAKING DEPOSITIONDUCES TECUM OF
 DEFENDANT'S DESIGNATED CORPORATE REPRESENTATIVE(S)WITH THE
 MOST KNOWLEDGE PURSUANT TO RULE 1.310(B)(6)
 THIS CAUSE having come before the Court on Motion for Protective Order as to Plaintiffs'
 Notice of Taking Zoom Deposition Duces Tecum, and Plaintiffs' Notice of Taking Deposition
 Duces Tecum of Defendant's Designated Corporate RepresentativeWith the Most Knowledge
 Pursuant to Rule 1.310(b)(6) and the Court having been advised that the attorneys for the
 respective parties have agreed and stipulated hereto, and being otherwisefully advised in the
 premises, it is hereby ORDERED and ADJUDGED that said Motion is GRANTED, as follows:
 1. Defendant's designated Corporate Representativeshall not answer questions regarding
 general claims practices, claims manuals, claim procedures and guidelines, business
 practices and policies.
 2. Defendant's designated Corporate Representativeshall not answer questions regarding
 work-product privileged information and privileged contents in the claim file.
 3. Defendant's designated Corporate Representativeshall not answer questions regarding
 Defendant'swork product communications with its field adjuster(s) and inspector(s).
 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/08/2021 06:49:09 PM.****
 CaseNo: CACE20017316
 Page 2 of 3
 4. Defendant's designated Corporate Representativeshall not answer questions regarding
 opinion of insurance policy interpretation and construction.
 5. Defendant's designated Corporate Representativeshall not answer questions regarding
 the underwriting file.
 6. Defendant is not required to produce its claim file, claim file contents, or any other item,
 including documents, photographs, reports, or other materials contained therein during
 the deposition. But the Corporate Representative will bring their file without waiving
 privilege or objection solely to refer to it in order to make the deposition more productive.
 7. Defendant shall not be required to produce its underwriting file or contents.
 8. The Defendant'sdesignated Corporate Representative shall not answer any question that
 is tailored to a claim of "bad faith."
 9. This Order shall not be read as Plaintiffs' waiver of the right to challenge Defendant's
 assertions of work product, privilege or relevance regarding the information and
 documents referenced herein following the deposition.
 10. This Order shall not affect Plaintiffs' right to move the Court to compel the production of
 any information, or documents claimed to be privileged, work product or irrelevant
 subsequent to the deposition of the Defendant's Corporate Representative.
 DONE and ORDERED in Chambers, at Broward County, Florida on 09-08-2021.
 c-*AFZWHA
 CACE20017316 09-08-2021 1:05 PM
 Hon. Mily R Powell
 CIRCUIT JUDGE
 Electronically Signed by Mily R Powell
 Copies Furnished To:
 Hope C. Zelinger E-mail :
 ,
 Hope C. Zelinger E-mail :
 ,
 Jesse N Bernheim, E-mail : rrios@bkbblaw.corn
 Jesse N Bernheim, E-mail :
 CaseNo: CACE20017316
 Page 3 of 3
 Linda M Berns, E-mail :
 Linda M Berns, E-mail :
 Linda M Berns, E-mail :
 Ludie Benel, E-mail : Ibenel@bressler.com
 Samantha Costello, E-mail: