Angeles-Delgado v. Benitez
Defendants in an auto negligence case sought certiorari to quash an order compelling Boecher-style discovery about the financial and professional relationships among their insurer, defense law firm, and retained experts. The Third DCA denied the petition, holding Worley is inapposite because it addressed only the attorney-client privilege barring disclosure of whether plaintiff's counsel referred the plaintiff to a treating physician, and thus does not shield non-party defense firms, insurers, or experts from Boecher discovery.
Key facts
- Defendants in an auto negligence case sought certiorari to quash a discovery order compelling production of information about financial and professional relationships among their insurer, defense law firm, and retained experts.
- The trial court ordered defendants to produce Boecher-style discovery regarding relationships between their insurer, defense counsel, and experts, and defendants argued the information should be protected under attorney-client privilege and Worley v. Central Florida YMCA.
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Why it matters
This decision places the Third DCA on the opposite side of the growing Worley/Boecher conflict from the Fourth and Fifth DCAs, which have certified questions of great public importance about whether Worley shields… — full analysis with a trial
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