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Filing # 117615684 E-Filed 12/03/2020 03:20:29 PM
IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
TOTAL CARE RESTORATION, LLC A/A/O
ANNIE GRIFFITHS,
Plaintiff,
Case No. COCE-19-023855
V.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
DEFENDANT’S AMENDED OBJECTIONS TO
PLAINTIFF’S NOTICE OF TAKING DEPOSITION OF LEE GENTRY,
CORPORATE REPRESENTATIVE(S) OF CITIZENS PROPERTY
INSURANCE CORPORATION AND MOTION FOR PROTECTIVE ORDER
Defendant, Citizens Property Insurance Corporation (“Citizens”), pursuant to Florida
Rules of Civil Procedure 1.280(c), 1.310(b), and 1.350(b), files its Objections to Plaintiff's
Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens Property
Insurance Corporation and Motion for Protective Order, and states:
Introduction
Citizens objects to the Plaintiff's Notice of Taking Deposition of Lee Gentry, Corporate
Representative(s) of Citizens Property Insurance Corporation on multiple bases, including
improper “bad faith” discovery of claim file and claim handling materials for both this and other
claims in this breach of contract action, over breadth, work-product privilege, attorney-client
privilege, privacy and confidentiality of personnel files, and irrelevance. In particular, discovery
of claim file and claim handling materials and information is in no way probative of the parties’
dispute in this case. Further, the Notice inappropriately lists who shall sit as Citizens’ Corporate
Representative, which is improper. Based on these objectionable requests, Citizens seeks a
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/03/2020 03:20:29 PM.**##
protective order prohibiting Plaintiff from discovering documents and information regarding
improper matters.
Factual Background
Plaintiff filed suit for declaratory judgment emanating from remediation services
allegedly provided in conjunction with a water loss suffered on the Property. Plaintiff served his
Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens Property
Insurance Corporation on October 14, 2020, 2020. (Ex. A)
Objections
By statute, “[a] policyholder who has filed suit against [Citizens] has the right to discover
the contents of his or her own claims file to the same extent that discovery of such contents
would be available from a private insurer in litigation as provided by the Florida Rules of Civil
Procedure, the Florida Evidence Code, and other applicable law.” § 627.351(6)(x)3., Fla. Stat.
Thus, the case law cited herein applies to Citizens just as it does to private insurers.
In this regard, and as background to Citizens’ objections set forth below, a party is not
entitled to discovery of an insurer’s claims file, documentation contained within the file,
documents relating to the insurer’s business policies and practices regarding the handling of
claims, or adjuster compensation or personnel materials in a first-party breach of contract action
because such is work-product privileged and protected. See Allstate Indem. Co. v. Ruiz, 899 So.
2d 1121 (Fla. 2005) (noting that a party is not entitled to discovery of an insurer’s claim file in an
action for insurance benefits combined with an action for bad faith until the insurer’s obligation
to provide coverage is established); State Farm Mut. Auto. Ins. Co. v. Tranchese, 49 So. 3d 809,
810 (Fla. 4th DCA 2010) (same and “holding that until the obligation to provide coverage and
damages has been determined, a party is not entitled to discovery related to the claims file or to
the insurer's business policies or practices regarding handling of claims”); Superior Ins. Co. v.
Holden, 632 So. 2d 1139, 1140 (Fla. 4th DCA 1994) (same); Nationwide Ins. Co. of Fla. v.
Demmo, 57 So. 3d 982 (Fla. 2d DCA 2011)(same, explaining that the question is not one
regarding whether the requested discovery is work-product but whether the action sounds in bad
faith or breach of contract); GEICO v. Rodriguez, 960 So. 2d 794, 795-96 (Fla. 3d DCA 2007)
(same, including “documents relating to the insurer's business policies or practices regarding the
handling of claims”); Old Republic Nat’l Title Ins. Co. v. Homeamerican Credit, Inc., 844 So. 2d
818, 819 (Fla. Sth DCA 2003) (same); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389, 390
(Fla. 2d DCA 2003) (same, including personnel files, company policies and manuals, details of
rewards and bonus programs for employees, and employee incentive and compensation
programs). Such discovery has only been deemed available in bad faith cases and not in any
other cases, such as this one for declaratory judgment. This is clearly not a bad faith case, and, in
fact, Citizens is sovereignly and statutorily immune from bad faith causes of action pursuant to
section 627.351(6)(s)1., Florida Statutes, and Citizens Property Insurance Corp. v. Garfinkel, 25
So. 3d 62 (Fla. 5th DCA 2009) (disapproved on other grounds by Citizens Prop. Ins. Corp. v.
San Perdido Ass'n, Inc., 104 So. 3d 344 (Fla. 2012)).
Additionally, corporate representative testimony regarding privileged and protected
claims handling documentation and information is similarly objectionable. J/linois Nat’l Ins. Co.
v. Bolen, 997 So. 2d 1194, 1195 (Fla. 5th DCA 2008) (holding that the trial court departed from
the essential requirements of law when it declined to grant the insurer’s motion for a protective
order where the notice of taking deposition duces tecum requested production of the insurer’
claims file); Am. Home Assur. Co. v. Vreeland, 973 So. 2d 668, 671 (Fla. 2d DCA 2008)
(deposition testimony by a corporate representative about privileged claim file materials is
prohibited); Scottsdale Ins. Co. v. Camara de Comercio Latino-Americana de Los Estados
Unidos, Inc., 813 So. 2d 250, 251 (Fla. 3d DCA 2002) (“The corporate representative may
testify, but cannot be compelled to testify as to the privileged matters.”).
Further, under Fla. R. Civ. P. 1.310(b)(6), the corporation designates the corporate
representative to sit for deposition. There is no requirement as to who shall sit nor is there any
requirement as to the knowledge the witness must possess. Fla. R. Civ. P. 1.310(b)(6) simply
requires the corporate representative to “testify about matters known or reasonably available to
the organization.” There is no requirement in Rule 1.310 or elsewhere to tender a representative
with the “most knowledge” about the specified topic(s). See, e.g., Carriage Hills Condo. Inc. v.
Jbh Roofing & Constructors, Inc., 109 So. 3d 329, 334 (Fla. 4th DCA 2013) (stating, “Rule
1.310(b)(6) does not require — or for that matter even contemplate — that the corporation produce
the witness with the “most knowledge” on the specified topic(s), and the witness is not required
to possess any personal knowledge at all.”). Therefore, the Notice is also improper insofar as it
designates the witness to sit as the corporate representative.
The Plaintiff has requested testimony regarding the following areas of inquiry:
Schedule “A”
4 Defendant’s inspections of the Property conducted 3 years or less prior to
Defendant’s issuance of insurance coverage for the Property;
15. Any and all documents in the Defendant’s underwriting file pertaining to this
Property
In accordance with the above-cited case law, Citizens would seek a protective order
regarding the above areas of inquiry insofar as the information sought violates the claim file
privilege, work product doctrine or is protected by other privilege.
Further, as Plaintiff is an Assignee of Benefits under the present claim, and not the
Insured, the Plaintiff has no right to discuss the Insured’s underwriting. Any request for
testimony regarding underwriting is irrelevant to any claim or defense in this first-party breach of
contract action and therefore not reasonably calculated to lead to the discovery of admissible
evidence.
Motion for Protective Order
Based on the objections set forth above, Citizens seeks a protective order regarding
Plaintiff's Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens
Property Insurance Corporation. Citizens asserts that it has demonstrated good cause establishing
that Plaintiff should be prevented from obtaining such discovery on the basis of annoyance,
embarrassment, oppression, or undue burden or expense. As such, Citizens is entitled to a
Protective Order pursuant to Florida Rule of Civil Procedure 1.280(c).
WHEREFORE, Defendant, Citizens Property Insurance Corporation, respectfully
requests this Court consider its Objections to Plaintiff's Notice of Taking Deposition of Lee
Gentry, Corporate Representative(s) of Citizens Property Insurance Corporation and Motion for
Protective Order, and enter a Protective Order prohibiting Plaintiff from: (1) discovering
otherwise privileged documents and information related to claim handling in this claim and other
claims in this action not for bad faith, but for breach of contract; and (2) discovering other
documents and information regarding which Citizens objected based on irrelevance, attorney-
client privilege, and other grounds, and all other relief this Court deems just and proper.
[o| Phillip S. Howell
PHILLIP S. HOWELL, Fla. Bar No. 377030
phowell@gallowaylawfirm.com
EDWARD N. KRAKAUER, Fla Bar No. 117797
ekrakauer@gallowaylawfirm.com
Galloway, Johnson, Tompkins, Burr & Smith, PLC
110 E. Broward Boulevard, Suite 1890
Fort Lauderdale, Florida 33301
(954) 951-2200
(954) 951-4400 (facsimile)
FLLservices allowaylawfirm.com
Counsel for Citizens Property Insurance Corporation
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following via the Florida Courts E-Filing Portal and/or electronic mail delivery December 3,
2020:
Michael D. Redondo, Esq.
Redondo Law, P.A.
2828 Coral Way, Suite 206
Miami, FL 33145
mike@redondolawfirm.com
ervice@redondolawfirm.com
Counsel for Plaintiff
[Phillip S. Howell
PHILLIP S. HOWELL
EDWARD N. KRAKAUER
EXHIBIT A
Filing # 114963401 E-Filed 10/14/2020 02:04:54 PM
IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
TOTAL CARE RESTORATION, LLC
A/A/O ANNIE GRIFFITHS,
CASE NO.: COCE-19-023855
Plaintiff,
Vv.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
NOTICE OF TAKING DEPOSITION
PLEASE TAKE NOTICE that the undersigned will take the deposition of the following
party:
NAME: Lee Gentry
Corporate Representative(s) of Citizens Property Insurance Corporation, on the
topics listed in the attached Exhibit A
DATE: December 16, 2020
TIME: 1:00 p.m.
PLACE: Universal Court Reporting
Via Zoom
upon oral examination before an officer authorized by law to take depositions. The oral
examination will continue from day to day until completed. This deposition is being taken for the
purpose of discovery, for use at trial, or for such other purposes as are permitted.
CERTIFICATE OF SERVICE
I certify that on October 14, 2020, I filed this document via the Florida Courts e-filing
portal which served the document on all counsel of record.
REDONDO LAW FIRM P.A.
Counsel for the Plaintiff
2828 Coral Way, Suite 201
Miami, FL 33145
Telephone: (305) 908-6778
Primary e-mail: mike@redondolawfirm.com
Secondary e-mail: service@redondolawfirm.com
By: /s/ Michael D. Redondo
Michael D. Redondo, Esq.
Florida Bar No. 86550
Exhibit A - Areas of Inquiry for Defendant’s Corporate Representative Deposition
1 Factual allegations in Defendant’s Answer and Affirmative Defenses;
2. Allegations in any pleading filed in this action by Plaintiff or Defendant;
3 Damages sustained as a result of the subject loss (the “Loss”) at the property as
described in the Complaint (the “Property”);
4. Defendant’s inspections of the Property conducted 3 years or less prior to
Defendant’s issuance of insurance coverage for the Property;
5 All written documentation provided by the Plaintiff, any insured of the Property,
or either of its representatives, to Defendant regarding the Loss;
6. All document requests from Defendant, or its representatives, to the Plaintiff, any
insured of the Property, or either of its representatives, relating to the Loss;
7
The name and contact information of all field adjusters, desk adjusters, and
supervisors that have performed any work on behalf of Defendant relating to the Loss;
8 The name and contact information of all non-privileged experts or insurance
adjusters that have performed any work pertaining to the Loss;
9 The name and contact information of all persons that inspected the Property after
the Loss;
10. All non-privileged information provided by any expert or insurance adjuster to the
Defendant, or its representatives, regarding the Property or the Loss;
11. Any and all communications between the Plaintiff, any insured of the Property, or
either of its representatives, and the Defendant relating to the Loss;
12. The name and contact information of all persons who made a coverage decision
relating to the Loss;
13. All non-privileged information relating to prior insurance claims filed with
Defendant and relating to the Property;
14. Any Civil Remedy Notices pertaining to this Loss and submitted against the
Defendant;
15. Any and all documents in the Defendant’s underwriting file pertaining to this
Property;
16. Repairs performed at the Property after the Loss;
17. Non-privileged reports prepared for or by Defendant relating to the value and/or
cause of the Loss;
18. Non-privileged reports prepared for or by Defendant regarding the cost of the
recommended repairs at the Property;
19. The name and contact information of all persons who were involved in the
coverage decision for the Loss; and
20. Any and all documents or answers provided in this action through discovery.
Preview
Filing # 117615684 E-Filed 12/03/2020 03:20:29 PM IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA TOTAL CARE RESTORATION, LLC A/A/O ANNIE GRIFFITHS, Plaintiff, Case No. COCE-19-023855 V. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT’S AMENDED OBJECTIONS TO PLAINTIFF’S NOTICE OF TAKING DEPOSITION OF LEE GENTRY, CORPORATE REPRESENTATIVE(S) OF CITIZENS PROPERTY INSURANCE CORPORATION AND MOTION FOR PROTECTIVE ORDER Defendant, Citizens Property Insurance Corporation (“Citizens”), pursuant to Florida Rules of Civil Procedure 1.280(c), 1.310(b), and 1.350(b), files its Objections to Plaintiff's Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens Property Insurance Corporation and Motion for Protective Order, and states: Introduction Citizens objects to the Plaintiff's Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens Property Insurance Corporation on multiple bases, including improper “bad faith” discovery of claim file and claim handling materials for both this and other claims in this breach of contract action, over breadth, work-product privilege, attorney-client privilege, privacy and confidentiality of personnel files, and irrelevance. In particular, discovery of claim file and claim handling materials and information is in no way probative of the parties’ dispute in this case. Further, the Notice inappropriately lists who shall sit as Citizens’ Corporate Representative, which is improper. Based on these objectionable requests, Citizens seeks a #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/03/2020 03:20:29 PM.**## protective order prohibiting Plaintiff from discovering documents and information regarding improper matters. Factual Background Plaintiff filed suit for declaratory judgment emanating from remediation services allegedly provided in conjunction with a water loss suffered on the Property. Plaintiff served his Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens Property Insurance Corporation on October 14, 2020, 2020. (Ex. A) Objections By statute, “[a] policyholder who has filed suit against [Citizens] has the right to discover the contents of his or her own claims file to the same extent that discovery of such contents would be available from a private insurer in litigation as provided by the Florida Rules of Civil Procedure, the Florida Evidence Code, and other applicable law.” § 627.351(6)(x)3., Fla. Stat. Thus, the case law cited herein applies to Citizens just as it does to private insurers. In this regard, and as background to Citizens’ objections set forth below, a party is not entitled to discovery of an insurer’s claims file, documentation contained within the file, documents relating to the insurer’s business policies and practices regarding the handling of claims, or adjuster compensation or personnel materials in a first-party breach of contract action because such is work-product privileged and protected. See Allstate Indem. Co. v. Ruiz, 899 So. 2d 1121 (Fla. 2005) (noting that a party is not entitled to discovery of an insurer’s claim file in an action for insurance benefits combined with an action for bad faith until the insurer’s obligation to provide coverage is established); State Farm Mut. Auto. Ins. Co. v. Tranchese, 49 So. 3d 809, 810 (Fla. 4th DCA 2010) (same and “holding that until the obligation to provide coverage and damages has been determined, a party is not entitled to discovery related to the claims file or to the insurer's business policies or practices regarding handling of claims”); Superior Ins. Co. v. Holden, 632 So. 2d 1139, 1140 (Fla. 4th DCA 1994) (same); Nationwide Ins. Co. of Fla. v. Demmo, 57 So. 3d 982 (Fla. 2d DCA 2011)(same, explaining that the question is not one regarding whether the requested discovery is work-product but whether the action sounds in bad faith or breach of contract); GEICO v. Rodriguez, 960 So. 2d 794, 795-96 (Fla. 3d DCA 2007) (same, including “documents relating to the insurer's business policies or practices regarding the handling of claims”); Old Republic Nat’l Title Ins. Co. v. Homeamerican Credit, Inc., 844 So. 2d 818, 819 (Fla. Sth DCA 2003) (same); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389, 390 (Fla. 2d DCA 2003) (same, including personnel files, company policies and manuals, details of rewards and bonus programs for employees, and employee incentive and compensation programs). Such discovery has only been deemed available in bad faith cases and not in any other cases, such as this one for declaratory judgment. This is clearly not a bad faith case, and, in fact, Citizens is sovereignly and statutorily immune from bad faith causes of action pursuant to section 627.351(6)(s)1., Florida Statutes, and Citizens Property Insurance Corp. v. Garfinkel, 25 So. 3d 62 (Fla. 5th DCA 2009) (disapproved on other grounds by Citizens Prop. Ins. Corp. v. San Perdido Ass'n, Inc., 104 So. 3d 344 (Fla. 2012)). Additionally, corporate representative testimony regarding privileged and protected claims handling documentation and information is similarly objectionable. J/linois Nat’l Ins. Co. v. Bolen, 997 So. 2d 1194, 1195 (Fla. 5th DCA 2008) (holding that the trial court departed from the essential requirements of law when it declined to grant the insurer’s motion for a protective order where the notice of taking deposition duces tecum requested production of the insurer’ claims file); Am. Home Assur. Co. v. Vreeland, 973 So. 2d 668, 671 (Fla. 2d DCA 2008) (deposition testimony by a corporate representative about privileged claim file materials is prohibited); Scottsdale Ins. Co. v. Camara de Comercio Latino-Americana de Los Estados Unidos, Inc., 813 So. 2d 250, 251 (Fla. 3d DCA 2002) (“The corporate representative may testify, but cannot be compelled to testify as to the privileged matters.”). Further, under Fla. R. Civ. P. 1.310(b)(6), the corporation designates the corporate representative to sit for deposition. There is no requirement as to who shall sit nor is there any requirement as to the knowledge the witness must possess. Fla. R. Civ. P. 1.310(b)(6) simply requires the corporate representative to “testify about matters known or reasonably available to the organization.” There is no requirement in Rule 1.310 or elsewhere to tender a representative with the “most knowledge” about the specified topic(s). See, e.g., Carriage Hills Condo. Inc. v. Jbh Roofing & Constructors, Inc., 109 So. 3d 329, 334 (Fla. 4th DCA 2013) (stating, “Rule 1.310(b)(6) does not require — or for that matter even contemplate — that the corporation produce the witness with the “most knowledge” on the specified topic(s), and the witness is not required to possess any personal knowledge at all.”). Therefore, the Notice is also improper insofar as it designates the witness to sit as the corporate representative. The Plaintiff has requested testimony regarding the following areas of inquiry: Schedule “A” 4 Defendant’s inspections of the Property conducted 3 years or less prior to Defendant’s issuance of insurance coverage for the Property; 15. Any and all documents in the Defendant’s underwriting file pertaining to this Property In accordance with the above-cited case law, Citizens would seek a protective order regarding the above areas of inquiry insofar as the information sought violates the claim file privilege, work product doctrine or is protected by other privilege. Further, as Plaintiff is an Assignee of Benefits under the present claim, and not the Insured, the Plaintiff has no right to discuss the Insured’s underwriting. Any request for testimony regarding underwriting is irrelevant to any claim or defense in this first-party breach of contract action and therefore not reasonably calculated to lead to the discovery of admissible evidence. Motion for Protective Order Based on the objections set forth above, Citizens seeks a protective order regarding Plaintiff's Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens Property Insurance Corporation. Citizens asserts that it has demonstrated good cause establishing that Plaintiff should be prevented from obtaining such discovery on the basis of annoyance, embarrassment, oppression, or undue burden or expense. As such, Citizens is entitled to a Protective Order pursuant to Florida Rule of Civil Procedure 1.280(c). WHEREFORE, Defendant, Citizens Property Insurance Corporation, respectfully requests this Court consider its Objections to Plaintiff's Notice of Taking Deposition of Lee Gentry, Corporate Representative(s) of Citizens Property Insurance Corporation and Motion for Protective Order, and enter a Protective Order prohibiting Plaintiff from: (1) discovering otherwise privileged documents and information related to claim handling in this claim and other claims in this action not for bad faith, but for breach of contract; and (2) discovering other documents and information regarding which Citizens objected based on irrelevance, attorney- client privilege, and other grounds, and all other relief this Court deems just and proper. [o| Phillip S. Howell PHILLIP S. HOWELL, Fla. Bar No. 377030 phowell@gallowaylawfirm.com EDWARD N. KRAKAUER, Fla Bar No. 117797 ekrakauer@gallowaylawfirm.com Galloway, Johnson, Tompkins, Burr & Smith, PLC 110 E. Broward Boulevard, Suite 1890 Fort Lauderdale, Florida 33301 (954) 951-2200 (954) 951-4400 (facsimile) FLLservices allowaylawfirm.com Counsel for Citizens Property Insurance Corporation CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the following via the Florida Courts E-Filing Portal and/or electronic mail delivery December 3, 2020: Michael D. Redondo, Esq. Redondo Law, P.A. 2828 Coral Way, Suite 206 Miami, FL 33145 mike@redondolawfirm.com ervice@redondolawfirm.com Counsel for Plaintiff [Phillip S. Howell PHILLIP S. HOWELL EDWARD N. KRAKAUER EXHIBIT A Filing # 114963401 E-Filed 10/14/2020 02:04:54 PM IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA TOTAL CARE RESTORATION, LLC A/A/O ANNIE GRIFFITHS, CASE NO.: COCE-19-023855 Plaintiff, Vv. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / NOTICE OF TAKING DEPOSITION PLEASE TAKE NOTICE that the undersigned will take the deposition of the following party: NAME: Lee Gentry Corporate Representative(s) of Citizens Property Insurance Corporation, on the topics listed in the attached Exhibit A DATE: December 16, 2020 TIME: 1:00 p.m. PLACE: Universal Court Reporting Via Zoom upon oral examination before an officer authorized by law to take depositions. The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted. CERTIFICATE OF SERVICE I certify that on October 14, 2020, I filed this document via the Florida Courts e-filing portal which served the document on all counsel of record. REDONDO LAW FIRM P.A. Counsel for the Plaintiff 2828 Coral Way, Suite 201 Miami, FL 33145 Telephone: (305) 908-6778 Primary e-mail: mike@redondolawfirm.com Secondary e-mail: service@redondolawfirm.com By: /s/ Michael D. Redondo Michael D. Redondo, Esq. Florida Bar No. 86550 Exhibit A - Areas of Inquiry for Defendant’s Corporate Representative Deposition 1 Factual allegations in Defendant’s Answer and Affirmative Defenses; 2. Allegations in any pleading filed in this action by Plaintiff or Defendant; 3 Damages sustained as a result of the subject loss (the “Loss”) at the property as described in the Complaint (the “Property”); 4. Defendant’s inspections of the Property conducted 3 years or less prior to Defendant’s issuance of insurance coverage for the Property; 5 All written documentation provided by the Plaintiff, any insured of the Property, or either of its representatives, to Defendant regarding the Loss; 6. All document requests from Defendant, or its representatives, to the Plaintiff, any insured of the Property, or either of its representatives, relating to the Loss; 7 The name and contact information of all field adjusters, desk adjusters, and supervisors that have performed any work on behalf of Defendant relating to the Loss; 8 The name and contact information of all non-privileged experts or insurance adjusters that have performed any work pertaining to the Loss; 9 The name and contact information of all persons that inspected the Property after the Loss; 10. All non-privileged information provided by any expert or insurance adjuster to the Defendant, or its representatives, regarding the Property or the Loss; 11. Any and all communications between the Plaintiff, any insured of the Property, or either of its representatives, and the Defendant relating to the Loss; 12. The name and contact information of all persons who made a coverage decision relating to the Loss; 13. All non-privileged information relating to prior insurance claims filed with Defendant and relating to the Property; 14. Any Civil Remedy Notices pertaining to this Loss and submitted against the Defendant; 15. Any and all documents in the Defendant’s underwriting file pertaining to this Property; 16. Repairs performed at the Property after the Loss; 17. Non-privileged reports prepared for or by Defendant relating to the value and/or cause of the Loss; 18. Non-privileged reports prepared for or by Defendant regarding the cost of the recommended repairs at the Property; 19. The name and contact information of all persons who were involved in the coverage decision for the Loss; and 20. Any and all documents or answers provided in this action through discovery.