On May 31, 1977 a
Party Discovery
was filed
involving a dispute between
Roberts, Berkley,
Roberts, Denise,
and
Tower Hill Prime Insurance Company,
for Insurance Claim
in the District Court of Charlotte County.
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Filing # 121659030 E-Filed 02/18/2021 03:46:25 PM
IN THE CIRCUIT COURT OF THE
TWENTIETH JUDICIAL CIRCUIT IN AND
FOR CHARLOTTE COUNTY, FLORIDA
CASE NO.: 20-CA-001073
BERKLEY ROBERTS AND DENISE
ROBERTS,
Plaintiffs,
vs.
TOWER HILL PRIME INSURANCE
COMPANY,
Defendant.
DEFENDANT’S PRIVILEGE LOG IN RESPONSE TO
PLAINTIFF’S REQUEST FOR PRODUCTION
COMES NOW, the Defendant, TOWER HILL PRIME INSURANCE COMPANY
(“TOWER HILL”), by and through the undersigned counsel, and hereby files this, its Privilege
Log in accordance with Florida Rule of Civil Procedure 1.280(b)(5) and in Response to Plaintiff's
Request for Production, and states as follows, and states as foll
OWS:
9/18/20
Document Date Author Recipient Subject Category
Type Matter of Privilege
Claims Notes Various | Various CH, WP, AP
ISO Report 3/20/20 N/A CH, WP
First Notice of 3/20/20
Loss
GeoHazard and 3/23/20, | GeoHazard GeoHazard | CH CH, WP
Defendant 4/8/20, and Def. and Def.
8/20/20,Document
Type
Date
Author
Recipient
Case No.: 20-CA-001073
Subject
Matter
Page 2
Category
of Privilege
GeoHazard
Assignment Form
GeoHazard
Invoice
Internal
documents
reflecting research
and investigation
into the claim,
claimant,
prepared by
and/or for the
adjusters at
TOWER HILL
handling the file
from its inception.
3/23/20
4/8/20
Various
GeoHazard
GeoHazard
Various,
GeoHazard
Def.
CH;
consultant
services
CH;
consultant
services
CH, WP
Underwriting File
Various
Def.’s
Underwriting
Personnel
Def.’s
Underwritin
g Personnel
Underwriting
* - As discovery is ongoing, Defendant reserves the right to amend its Privilege Log.Case No.: 20-CA-001073
Page 3
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via Electronic Mail, to all counsel of record on the attached Service List, this 18th day of February,
2021.
LUKS, SANTANIELLO, PETRILLO &
COHEN
Attorneys for Defendant
110 SE 6TH STREET
20TH FLOOR
FORT LAUDERDALE, FL 33301
Telephone: (954) 761-9900
Facsimile: (954) 761-9940
By:__/s/ Brittany L. Ehrenman
William J. Peterfriend
Florida Bar No.: 544647
Brittany L. Ehrenman
Florida Bar No.: 1010954
LUKSFLL-Pleadings@LS-Law.com
SERVICE LIST
Shaun J. MArker, Esq.
MERLIN LAW GROUP, P.A.
222 Lakeview Avenue, Suite 1250
West Palm Beach, FL 33401
smarker@merlinlawgroup.com
rgregory@merlinlawgroup.com
dmyskowski@merlinlawgroup.com
ksantangelo@merlinlawgroup.com
Document Filed Date
February 18, 2021
Case Filing Date
May 31, 1977
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Filing # 121659030 E-Filed 02/18/2021 03:46:25 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO.: 20-CA-001073 BERKLEY ROBERTS AND DENISE ROBERTS, Plaintiffs, vs. TOWER HILL PRIME INSURANCE COMPANY, Defendant. DEFENDANT’S PRIVILEGE LOG IN RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION COMES NOW, the Defendant, TOWER HILL PRIME INSURANCE COMPANY (“TOWER HILL”), by and through the undersigned counsel, and hereby files this, its Privilege Log in accordance with Florida Rule of Civil Procedure 1.280(b)(5) and in Response to Plaintiff's Request for Production, and states as follows, and states as foll OWS: 9/18/20 Document Date Author Recipient Subject Category Type Matter of Privilege Claims Notes Various | Various CH, WP, AP ISO Report 3/20/20 N/A CH, WP First Notice of 3/20/20 Loss GeoHazard and 3/23/20, | GeoHazard GeoHazard | CH CH, WP Defendant 4/8/20, and Def. and Def. 8/20/20,Document Type Date Author Recipient Case No.: 20-CA-001073 Subject Matter Page 2 Category of Privilege GeoHazard Assignment Form GeoHazard Invoice Internal documents reflecting research and investigation into the claim, claimant, prepared by and/or for the adjusters at TOWER HILL handling the file from its inception. 3/23/20 4/8/20 Various GeoHazard GeoHazard Various, GeoHazard Def. CH; consultant services CH; consultant services CH, WP Underwriting File Various Def.’s Underwriting Personnel Def.’s Underwritin g Personnel Underwriting * - As discovery is ongoing, Defendant reserves the right to amend its Privilege Log.Case No.: 20-CA-001073 Page 3 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List, this 18th day of February, 2021. LUKS, SANTANIELLO, PETRILLO & COHEN Attorneys for Defendant 110 SE 6TH STREET 20TH FLOOR FORT LAUDERDALE, FL 33301 Telephone: (954) 761-9900 Facsimile: (954) 761-9940 By:__/s/ Brittany L. Ehrenman William J. Peterfriend Florida Bar No.: 544647 Brittany L. Ehrenman Florida Bar No.: 1010954 LUKSFLL-Pleadings@LS-Law.com SERVICE LIST Shaun J. MArker, Esq. MERLIN LAW GROUP, P.A. 222 Lakeview Avenue, Suite 1250 West Palm Beach, FL 33401 smarker@merlinlawgroup.com rgregory@merlinlawgroup.com dmyskowski@merlinlawgroup.com ksantangelo@merlinlawgroup.com