Hidalgo v. Citizens Property Insurance Corp.
In a first-party property insurance suit, the trial court ordered the homeowners' retained expert engineer to produce a list of cases with, and money received over three years from, the homeowners' law firm. On certiorari, the Third DCA held Worley's attorney-client holding is limited to whether a plaintiff's lawyer referred the plaintiff to a treating physician and does not bar this discovery, but quashed the order because Rule 1.280(b)(5)(A)(iii) permits expert financial and business record discovery beyond the enumerated categories only on a showing of 'the most unusual or compelling circumstances,' which the record and order lacked.
Key facts
- Homeowners retained an expert engineer in a first-party property insurance dispute against Citizens Property Insurance Corp.
- Trial court ordered the expert to produce a list of cases and money received over three years from the homeowners' law firm.
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Why it matters
This opinion gives defense and plaintiff counsel a clear framework for expert-bias discovery: Worley is narrowly cabined to treating-physician referral questions, but Rule 1.280(b)(5)(A)(iii)'s 'most unusual or… — full analysis with a trial
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