Motion For Protective Order: Work Product and Attorney Client Privileges; Waiver

State Farm Florida Insurance Company v. Kramer, ___ So. 3d ___, 35 Fla. L. Weekly D1558 (Fla. 4th DCA 7/14/10)

An insurance company did not waive its work product and attorney client privileges by not objecting to the plaintiff’s request to produce, but instead moving for a protective order on the ground that the plaintiff in an action for breach of contract was not legally entitled to production of the insurer’s claim and underwriting files and documents from the insurance company’s litigation file.