On April 05, 2021 a
Party Discovery
was filed
involving a dispute between
Samhoury, Chryssa,
Samhoury, Samer,
and
Centauri Specialty Insurance Company,
for Civil
in the District Court of Hillsborough County.
Preview
Filing # 127774576 E-Filed 05/28/2021 03:03:50 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SAMER SAMHOURY and
CHRYSSA SAMHOURY,
Plaintiff(s),
vs. Case No.: 21-CA-002884
DIV. C
CENTAURI SPECIALTY INSURANCE
COMPANY,
Defendant(s).
______________________________________/
DEFENDANT’S LOG OF DOCUMENTS WITHHELD FROM PRODUCTION
Pursuant to Rule 1.280(b)(5), Florida Rules of Civil Procedure, Defendant, CENTAURI
SPECIALTY INSURANCE COMPANY (hereinafter, “CENTAURI”), by and through its
undersigned attorneys, identifies the following documents as privileged and/or withheld from
discovery:
DATE AUTHOR DESCRIPTION OF BASIS FOR CLAIM OF
DOCUMENT PRIVILEGE
Various Various employees and Claim Notes Attorney-Client Privilege. Work
dates agents of Centauri product doctrine/claims
handling/personal thoughts of
CENTAURI employees and/or agents.
Fla. R. Civ. P. 1.280(b)(3); Nationwide
Ins. Co. of Fla. v. Demmo, 57 So. 3d
982, 984 (Fla. 2d DCA 2011); State
Farm Florida Ins. Co. v. Gallmon, 835
So. 2d 389 (Fla. 2d DCA 2003); State
Farm Fire & Cas. Co. v. Valido, 662
So. 2d 1012 (Fla. 3d DCA 1995);
Anchor Nat'l Fin. Servs., Inc. v. Smeltz,
546 So. 2d 760 (Fla. 2d DCA 1989);
Florida Cypress Gardens, Inc. v.
Murphy, 471 So.2d 203 (Fla. 2d DCA
1985); Utica Mutual Ins. Co. v. Croft,
432 So.2d 196 (Fla. 1st 1983); Seminole
Cas. Ins. Co. v. Mastrominas, 6 So.3d
1256 (Fla. 2d DCA 2009); Home Assur.
1
5/28/2021 3:03 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
Co. v. Vreeland, 973 So.2d 668 (Fla. 2d
DCA 2008).
Unknown Employee/agent of Notice of Loss Same as above.
Centauri
Various Employees/agents of Internal emails Same as above.
Centauri
Various IMS Claims Services Correspondence with Same as above.
Centauri
5/8/2019 Employees/agents of ISO Claim Search report Same as above.
Centauri
5/9/2019 Employees/agents of Dexter Event report Same as above.
Centauri
5/9/2019 Employees/agents of Email to Accurate Same as above.
Centauri Insurance Mart Agency
5/21/2019 IMS Claims Services Reserve Status/Update Same as above.
Report
5/24/2019 IMS Claims Services Reserve Status/Update Same as above.
Report
6/5/2019 IMS Claims Services First Report with adjuster Same as above.
photographs; diagram
sheet; and estimate
6/5/2019 IMS Claims Services Reserve Report with Same as above.
photographs
6/10/2019 Employees/agents of Email with FCG Same as above.
Centauri Associates
6/18/2019 IMS Claims Services Second Report with Same as above.
statement of loss and
estimate
6/28/2019 IMS Claims Services Third Report Same as above.
7/13/2019 FCG Associates Service Invoice Same as above.
8/12/2019 IMS Claims Services Fourth and Final Report Same as above.
with statement of loss,
estimate, engineer report,
activity report and
invoice
Defendant reserves its right to amend and/or supplement as discovery is ongoing.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the foregoing pleading was sent by
electronic mail on this 28th day of May 2021, to Counsel for Plaintiff listed below:
Kevin E. Vorhis, Esquire (FBN: 118482)
2
5/28/2021 3:03 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
COHEN LAW GROUP
350 North Lake Destiny Road
Maitland, FL 32751
Phone: 407-478-4878
Fax: 407-478-0204
Email: kvorhis@itsaboutjustice.law
Email: rachael@itsaboutjustice.law
Attorneys for Plaintiffs
ZINOBER DIANA & MONTEVERDE, P.A.
___________________________________
Fredric S. Zinober, Esq. (FBN: 0341657)
E-Service: Fred@zinoberdiana.com
E-Service: Shannon@zinoberdiana.com
Michelle E. Sabin, Esquire (FBN: 0059471)
E-Service: Michelle@zinoberdiana.com
E-Service: Pam@zinoberdiana.com
607 West Horatio Street
Tampa, FL 33606
Phone: 813-642-4229
Fax: 727-498-8902
Attorneys for Defendant
3
5/28/2021 3:03 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
Document Filed Date
May 28, 2021
Case Filing Date
April 05, 2021
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Filing # 127774576 E-Filed 05/28/2021 03:03:50 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SAMER SAMHOURY and CHRYSSA SAMHOURY, Plaintiff(s), vs. Case No.: 21-CA-002884 DIV. C CENTAURI SPECIALTY INSURANCE COMPANY, Defendant(s). ______________________________________/ DEFENDANT’S LOG OF DOCUMENTS WITHHELD FROM PRODUCTION Pursuant to Rule 1.280(b)(5), Florida Rules of Civil Procedure, Defendant, CENTAURI SPECIALTY INSURANCE COMPANY (hereinafter, “CENTAURI”), by and through its undersigned attorneys, identifies the following documents as privileged and/or withheld from discovery: DATE AUTHOR DESCRIPTION OF BASIS FOR CLAIM OF DOCUMENT PRIVILEGE Various Various employees and Claim Notes Attorney-Client Privilege. Work dates agents of Centauri product doctrine/claims handling/personal thoughts of CENTAURI employees and/or agents. Fla. R. Civ. P. 1.280(b)(3); Nationwide Ins. Co. of Fla. v. Demmo, 57 So. 3d 982, 984 (Fla. 2d DCA 2011); State Farm Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); Anchor Nat'l Fin. Servs., Inc. v. Smeltz, 546 So. 2d 760 (Fla. 2d DCA 1989); Florida Cypress Gardens, Inc. v. Murphy, 471 So.2d 203 (Fla. 2d DCA 1985); Utica Mutual Ins. Co. v. Croft, 432 So.2d 196 (Fla. 1st 1983); Seminole Cas. Ins. Co. v. Mastrominas, 6 So.3d 1256 (Fla. 2d DCA 2009); Home Assur. 1 5/28/2021 3:03 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 Co. v. Vreeland, 973 So.2d 668 (Fla. 2d DCA 2008). Unknown Employee/agent of Notice of Loss Same as above. Centauri Various Employees/agents of Internal emails Same as above. Centauri Various IMS Claims Services Correspondence with Same as above. Centauri 5/8/2019 Employees/agents of ISO Claim Search report Same as above. Centauri 5/9/2019 Employees/agents of Dexter Event report Same as above. Centauri 5/9/2019 Employees/agents of Email to Accurate Same as above. Centauri Insurance Mart Agency 5/21/2019 IMS Claims Services Reserve Status/Update Same as above. Report 5/24/2019 IMS Claims Services Reserve Status/Update Same as above. Report 6/5/2019 IMS Claims Services First Report with adjuster Same as above. photographs; diagram sheet; and estimate 6/5/2019 IMS Claims Services Reserve Report with Same as above. photographs 6/10/2019 Employees/agents of Email with FCG Same as above. Centauri Associates 6/18/2019 IMS Claims Services Second Report with Same as above. statement of loss and estimate 6/28/2019 IMS Claims Services Third Report Same as above. 7/13/2019 FCG Associates Service Invoice Same as above. 8/12/2019 IMS Claims Services Fourth and Final Report Same as above. with statement of loss, estimate, engineer report, activity report and invoice Defendant reserves its right to amend and/or supplement as discovery is ongoing. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the foregoing pleading was sent by electronic mail on this 28th day of May 2021, to Counsel for Plaintiff listed below: Kevin E. Vorhis, Esquire (FBN: 118482) 2 5/28/2021 3:03 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 COHEN LAW GROUP 350 North Lake Destiny Road Maitland, FL 32751 Phone: 407-478-4878 Fax: 407-478-0204 Email: kvorhis@itsaboutjustice.law Email: rachael@itsaboutjustice.law Attorneys for Plaintiffs ZINOBER DIANA & MONTEVERDE, P.A. ___________________________________ Fredric S. Zinober, Esq. (FBN: 0341657) E-Service: Fred@zinoberdiana.com E-Service: Shannon@zinoberdiana.com Michelle E. Sabin, Esquire (FBN: 0059471) E-Service: Michelle@zinoberdiana.com E-Service: Pam@zinoberdiana.com 607 West Horatio Street Tampa, FL 33606 Phone: 813-642-4229 Fax: 727-498-8902 Attorneys for Defendant 3 5/28/2021 3:03 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3