United Healthcare Services, Inc., etc., et al. v. Benjamin Cousins, M.D., P.A.
The Third District denied United Healthcare's certiorari petition seeking to quash a broad document production order. Given the trial court's wide discretion over discovery and the demanding certiorari standard, the panel found no departure from the essential requirements of law — particularly where the petitioners had themselves relied on the same data and had obtained an order compelling the respondent to produce the same category of documents. Burden evidence submitted only after the hearing, with a motion for reconsideration, could not carry the petition.
Key facts
- Benjamin Cousins, M.D., P.A. sued United Healthcare Services, Inc. and related entities in the Circuit Court for Miami-Dade County (Judge Abby Cynamon).
- The trial court entered an order requiring United Healthcare to produce a voluminous number of documents, and United Healthcare petitioned the Third District for a writ of certiorari to quash that order.
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Holdings
- Trial courts are accorded broad discretion in the treatment of discovery problems, and a discovery order reviewed by certiorari will not be quashed absent a departure from the essential…
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Why it matters
This decision is a practical roadmap for litigating — and resisting — overbreadth and undue-burden objections to sweeping document requests in commercial and payer-provider disputes. Two takeaways matter most: first, a… — full analysis with a trial
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