Ann Hamilton v. Citizens Property Insurance Corporation
In a first-party property insurance suit, the trial court entered a protective order allowing Citizens' corporate representative to review privileged claim-file materials to refresh his recollection at deposition while barring the plaintiff from seeing or cross-examining on those materials. The Third District granted certiorari and quashed that portion of the order, holding it departed from the essential requirements of law under section 90.613, Florida Statutes.
Key facts
- Ann Hamilton sued Citizens Property Insurance Corporation in a first-party property insurance claim.
- The trial court issued a protective order permitting Citizens' corporate representative to review privileged claim-file materials to refresh his recollection at deposition, but prohibited Hamilton from viewing or cross-examining on those materials.
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Why it matters
This opinion gives litigators a direct authority that a corporate representative cannot use privileged claim-file or other documents to refresh recollection at deposition while withholding them from the examining party… — full analysis with a trial
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