Villalobos v. Martinez
In a personal-injury discovery dispute, the Third DCA denied certiorari review of an order addressing disclosure of the financial relationship between a non-party law firm/insurer and retained experts, citing Worley v. Central Florida YMCA and its own recent decision in Angeles-Delgado v. Benitez. The court expressly noted contrary authority from the Fourth and Fifth DCAs, which have certified questions of great public importance on whether Worley extends to defense firms and insurers, with review pending in the Florida Supreme Court.
Key facts
- Villalobos sought discovery regarding the financial relationship between a non-party law firm/insurer and retained experts in a personal-injury case.
- The trial court entered an order addressing disclosure of the financial relationship, and Villalobos petitioned for certiorari review in the Third District Court of Appeal.
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Why it matters
This opinion places the Third DCA on the plaintiff-friendly side of the developing Worley expert-bias discovery split, signaling that in Miami-Dade cases the court will not grant certiorari to compel disclosure of a… — full analysis with a trial
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