On October 18, 2019 a
Party Discovery
was filed
involving a dispute between
Chaudhari, Hemendra,
Chaudhari, Kamla,
and
Safepoint Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
Preview
Filing # 112424936 E-Filed 08/26/2020 02:55:19 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
KAMLA CHAUDHARI and
HEMENDRA CHAUDHARI,
Plaintiffs,
v. Case No.: CACE-19-021689
SAFEPOINT INSURANCE COMPANY,
Defendant.
/
DEFENDANT, SAFEPOINT INSURANCE COMPANY’S PRIVILEGE LOG
Comes now, SAFEPOINT INSURANCE COMPANY (“SAFEPOINT”) by and through
its undersigned counsel, and hereby provides its Privilege Log.
Subject/ Date Author Recipient | Custody Privilege
Description
(Claim Notes 12/9/19— | Various Internal File} SAFEPOINT | Claims Material,
Present Work Product
Note S/I7/19 Pioneer Internal File} SAFEPOINT | Claims Material,
Roofing Work Product,
Consulting-Expert
Invoice S/17/19 Pioneer Internal File} SAFEPOINT | Claims Material,
Roofing Work Product,
Consulting-Expert
[SO Claim Search | 4/2/19 SafePoint Internal File} SAFEPOINT | Claims Material,
Work Product
[Loss Report A/I/19 SafePoint Internal File | SAFEPOINT _ | Claims Material,
Work Product
[Invoice 4/16/19 SafePoint Internal File | SAFEPOINT _ | Claims Material,
Work Product
[Report 4/16/19 Geomni Roof | Internal File} SAFEPOINT __| Claims Material,
Work Product
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/26/2020 02:55:18 PM.****[Internal emails Various Various
Internal File | SAFEPOINT _ | Claims Material,
Work Product
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on this 26" day of August 2020, a true and correct copy of the
foregoing was filed with the Clerk of Court by using the Florida court’s e-filing portal, which will
send an automatic email message to the following parties registered with the e-filing portal system:
Neil M. Khan, Esq., The Khan Law Firm,
1521 Alton Road, Suite 784, Miami Beach, Florida
33139 | neilk@khanlaw.attomey (Counsel for Plaintiffs)
By:
/s/ Stefanie L. Rosen
Stefanie L. Rosen, Esq.
Florida Bar No.: 99355
SafePoint Insurance Company
P.O. Box 291579
Tampa, Florida 33687
Email: srosen@safepointins.com;
ahin@safepointins.com
Phone: (813) 296-8506 / Fax: (813) 534-5108
Counsel for Defendant, SafePoint Insurance Company
Document Filed Date
August 26, 2020
Case Filing Date
October 18, 2019
Category
Other - Insurance Claim
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Filing # 112424936 E-Filed 08/26/2020 02:55:19 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA KAMLA CHAUDHARI and HEMENDRA CHAUDHARI, Plaintiffs, v. Case No.: CACE-19-021689 SAFEPOINT INSURANCE COMPANY, Defendant. / DEFENDANT, SAFEPOINT INSURANCE COMPANY’S PRIVILEGE LOG Comes now, SAFEPOINT INSURANCE COMPANY (“SAFEPOINT”) by and through its undersigned counsel, and hereby provides its Privilege Log. Subject/ Date Author Recipient | Custody Privilege Description (Claim Notes 12/9/19— | Various Internal File} SAFEPOINT | Claims Material, Present Work Product Note S/I7/19 Pioneer Internal File} SAFEPOINT | Claims Material, Roofing Work Product, Consulting-Expert Invoice S/17/19 Pioneer Internal File} SAFEPOINT | Claims Material, Roofing Work Product, Consulting-Expert [SO Claim Search | 4/2/19 SafePoint Internal File} SAFEPOINT | Claims Material, Work Product [Loss Report A/I/19 SafePoint Internal File | SAFEPOINT _ | Claims Material, Work Product [Invoice 4/16/19 SafePoint Internal File | SAFEPOINT _ | Claims Material, Work Product [Report 4/16/19 Geomni Roof | Internal File} SAFEPOINT __| Claims Material, Work Product *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/26/2020 02:55:18 PM.****[Internal emails Various Various Internal File | SAFEPOINT _ | Claims Material, Work Product CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that on this 26" day of August 2020, a true and correct copy of the foregoing was filed with the Clerk of Court by using the Florida court’s e-filing portal, which will send an automatic email message to the following parties registered with the e-filing portal system: Neil M. Khan, Esq., The Khan Law Firm, 1521 Alton Road, Suite 784, Miami Beach, Florida 33139 | neilk@khanlaw.attomey (Counsel for Plaintiffs) By: /s/ Stefanie L. Rosen Stefanie L. Rosen, Esq. Florida Bar No.: 99355 SafePoint Insurance Company P.O. Box 291579 Tampa, Florida 33687 Email: srosen@safepointins.com; ahin@safepointins.com Phone: (813) 296-8506 / Fax: (813) 534-5108 Counsel for Defendant, SafePoint Insurance Company