On December 15, 2015 a
Stipulation,Agreement
was filed
involving a dispute between
Chase, Judith,
and
St. Johns Ins Co Inc,
for Other - Insurance Claim
in the District Court of Broward County.
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**** FILED: BROWARD COUNTY, FL Howard C. Forman, CLERK 5/16/2016 8:07:32 AM.****
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-15-022063 DIV. 18
JUDITH CHASE,
Plaintiff,
ST. JOHNS INSURANCE COMPANY, INC.,
Defendant.
/
AGREED ORDER ON DEFENDANT'S
MOTION FOR PROTECTIVE ORDER
THIS CAUSE having come to be considered in lieu of the Defendant filing a Motion for
Protective Order, and upon agreement of counsel, and the Court being fully advised of the
premises, it is hereby:
ORDERED AND ADJUDGED that:
1, The Corporate Representative shall appear with St. Johns’ entire file for the sole
purpose to refresh his/her recollection and allow competent testimony at deposition.
2. The claim file will not be produced to Plaintiff during the deposition. Defendant’s
agreement to bring the claim file to the deposition does not constitute a waiver that same is
irrelevant to this Breach of Contract action and/or protected from disclosure by the work product
doctrine and attorney-client privilege. Further, Defendant’s agreement does not waive any
objections set forth in its responses to Plaintiff's discovery requests and Privilege Log.
3. The Corporate Representative shall not be required to produce any documents in
his/her file unless Defendant anticipates relying on said documents in a Motion for Summary
Judgment or at Trial, or the Court orders production of said documents. Defendant will produce
the documents it intends to rely upon in accordance with the applicable trial order or at the time it
files any dispositive motions, or in accordance with any order of the Court.CASE NO,: CACE-15-022063 DIV. 18
4. The Corporate Representative’s testimony will be limited to the corporation’s
knowledge of the specified topics.
5. Defendant preserves any and all objections previously stated in discovery.
DONE AND ORDERED in Chambers at Broward County, Florida, this VA 6 ae
day of / 1 an » 2016,
CIRCUIT COURT JUDGE
Copies furnished to:
Marybeth Cullinan, Esq.
Peter J. Mineo, Esq.
Document Filed Date
May 16, 2016
Case Filing Date
December 15, 2015
Category
Other - Insurance Claim
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**** FILED: BROWARD COUNTY, FL Howard C. Forman, CLERK 5/16/2016 8:07:32 AM.**** IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-15-022063 DIV. 18 JUDITH CHASE, Plaintiff, ST. JOHNS INSURANCE COMPANY, INC., Defendant. / AGREED ORDER ON DEFENDANT'S MOTION FOR PROTECTIVE ORDER THIS CAUSE having come to be considered in lieu of the Defendant filing a Motion for Protective Order, and upon agreement of counsel, and the Court being fully advised of the premises, it is hereby: ORDERED AND ADJUDGED that: 1, The Corporate Representative shall appear with St. Johns’ entire file for the sole purpose to refresh his/her recollection and allow competent testimony at deposition. 2. The claim file will not be produced to Plaintiff during the deposition. Defendant’s agreement to bring the claim file to the deposition does not constitute a waiver that same is irrelevant to this Breach of Contract action and/or protected from disclosure by the work product doctrine and attorney-client privilege. Further, Defendant’s agreement does not waive any objections set forth in its responses to Plaintiff's discovery requests and Privilege Log. 3. The Corporate Representative shall not be required to produce any documents in his/her file unless Defendant anticipates relying on said documents in a Motion for Summary Judgment or at Trial, or the Court orders production of said documents. Defendant will produce the documents it intends to rely upon in accordance with the applicable trial order or at the time it files any dispositive motions, or in accordance with any order of the Court.CASE NO,: CACE-15-022063 DIV. 18 4. The Corporate Representative’s testimony will be limited to the corporation’s knowledge of the specified topics. 5. Defendant preserves any and all objections previously stated in discovery. DONE AND ORDERED in Chambers at Broward County, Florida, this VA 6 ae day of / 1 an » 2016, CIRCUIT COURT JUDGE Copies furnished to: Marybeth Cullinan, Esq. Peter J. Mineo, Esq.