On December 20, 2019 a
Letter,Correspondence
was filed
involving a dispute between
Cmr Construction & Roofing Llc,
and
Olympus Insurance Company,
for Contract and Indebtedness
in the District Court of Collier County.
Preview
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IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CMR CONSTRUCTION & ROOFING, LLC CASE NO.: 11-2019-CA-004953-0001-XX
A/A/O LAWRENCE JULIANO and
SHEILA JULIANO,
Plaintiff,
vs.
OLYMPUS INSURANCE COMPANY,
Defendant.
_/
AGREED ORDER ON DEFENDANT'S MOTION FOR PROTECTIVE ORDER FOR THE
DEPOSITION OF THE CORPORATE REPRESENTATIVE
THIS CAUSE having come before this Court on Defendant, OLYMPUS INSURANCE
COMPANY’s Motion for Protective Order for the Deposition of the Corporate Representative,
and the Court having been fully advised in the premises, and the parties being in
agreement, it is hereby
ORDERED AND ADJUDGED that:
1. Defendant’s Motion is granted in part.
2. The Corporate Representative of Olympus Insurance Company shall not testify
about information that is specific to bad faith causes of action and/or any information
protected from disclosure by attorney/client and work product privileges.
3. The Corporate Representative of Olympus Insurance Company may refer to
privileged material to refresh his/her recollection without waiver of asserted privilege and
this privileged material will not be produced during the deposition. Olympus Insurance
FILEMLQ/16720 1457 Col Liercoa
Company's agreement to bring privileged material to the deposition does not waive any
objections set forth in its responses to Plaintiffs’ discovery requests.
4. The Corporate Representative of Olympus Insurance Company shall not be
asked to interpret the policy at issue, specifically questions shall not be asked that infer or
request legal construction of the policy.
5. This Order shall not preclude Olympus Insurance Company from objecting to
questions it deems are relevant to bad faith causes of action or otherwise not relevant to first
party breach of contract actions.
DONE and ORDERED in Chambers at Collier County, Florida this Is day of
“ Fa Pas
CIRCUIT COURT JUDGE
Copies furnished to:
Gabriela Rodriguez, Esq.
Stone, Glass & Connolly, LLP
15321 S. Dixie Highway, Suite 308
Palmetto Bay, FL 33157
grodriguez@sgc-attorneys.com ; yarenas@sgc-attorneys.com
Rick C. Briggs, Esq.
Kanner & Pintaluga, P.A.
3615 E. Frontage Road
Tampa, FL 33607
i ; cbriggs@kpattorney.com;
apadgett@kpattorney.com
Case Filing Date
December 20, 2019
Category
Contract and Indebtedness
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NN IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CMR CONSTRUCTION & ROOFING, LLC CASE NO.: 11-2019-CA-004953-0001-XX A/A/O LAWRENCE JULIANO and SHEILA JULIANO, Plaintiff, vs. OLYMPUS INSURANCE COMPANY, Defendant. _/ AGREED ORDER ON DEFENDANT'S MOTION FOR PROTECTIVE ORDER FOR THE DEPOSITION OF THE CORPORATE REPRESENTATIVE THIS CAUSE having come before this Court on Defendant, OLYMPUS INSURANCE COMPANY’s Motion for Protective Order for the Deposition of the Corporate Representative, and the Court having been fully advised in the premises, and the parties being in agreement, it is hereby ORDERED AND ADJUDGED that: 1. Defendant’s Motion is granted in part. 2. The Corporate Representative of Olympus Insurance Company shall not testify about information that is specific to bad faith causes of action and/or any information protected from disclosure by attorney/client and work product privileges. 3. The Corporate Representative of Olympus Insurance Company may refer to privileged material to refresh his/her recollection without waiver of asserted privilege and this privileged material will not be produced during the deposition. Olympus Insurance FILEMLQ/16720 1457 Col Liercoa Company's agreement to bring privileged material to the deposition does not waive any objections set forth in its responses to Plaintiffs’ discovery requests. 4. The Corporate Representative of Olympus Insurance Company shall not be asked to interpret the policy at issue, specifically questions shall not be asked that infer or request legal construction of the policy. 5. This Order shall not preclude Olympus Insurance Company from objecting to questions it deems are relevant to bad faith causes of action or otherwise not relevant to first party breach of contract actions. DONE and ORDERED in Chambers at Collier County, Florida this Is day of “ Fa Pas CIRCUIT COURT JUDGE Copies furnished to: Gabriela Rodriguez, Esq. Stone, Glass & Connolly, LLP 15321 S. Dixie Highway, Suite 308 Palmetto Bay, FL 33157 grodriguez@sgc-attorneys.com ; yarenas@sgc-attorneys.com Rick C. Briggs, Esq. Kanner & Pintaluga, P.A. 3615 E. Frontage Road Tampa, FL 33607 i ; cbriggs@kpattorney.com; apadgett@kpattorney.com