Privilege Log
2
1 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA STEVEN POULOS, Plaintiff, vs. CASE NO.: 11-23833 ALLSTATE INSURANCE COMPANY, RMK INSURANCE GROUP, INC. and JOSE KUDJA, individually, and, REBECCA KUDJA, individually Defendants. / DEFENDANT, ALLSTATE INSURANCE COMPANY’S, PRIVILEGE LOG Defendant, Allstate Insurance Company, files its privilege log regarding documents requested in Plaintiff’s Second Request to Produce. Document Description Privilege Asserted Compliance review summaries prepared by Allstate compliance analyst Joe Cackowski. Work Product Emails from Allstate compliance analyst Joe Cackowski to Allstate’s Florida HR manager and Controller Department supervisors regarding summaries of compliance reviews Work Product Emails from Allstate’s Florida HR manager to Corporate Security regarding summaries of compliance reviews Work Product Letter from Allstate in-house counsel to Allstate Corporate Security Department regarding opening investigation into the RMK Insurance Agency Attorney-Client & Work Product Correspondence (involving only Allstate employees) to and from Corporate Security investigators regarding investigation of the RMK Insurance Agency Attorney-Client & Work Product Allstate CIP reports obtained by Corporate Security Department as part of its investigation of the RMK Insurance Agency Attorney-Client & Work Product Corporate Security’s video interviews with employees of the RMK Insurance Agency as part of Corporate Security’s investigation of the RMK Agency Attorney-Client & Work Product Corporate Security’s audio interview with employee of the RMK Insurance Agency as part of Corporate Security’s investigation of the RMK Agency Attorney-Client & Work Product
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Investigation correspondence as well as audio/video interview of RMK Employee withheld. Was this even reported to the Florida Department of Insurance? Hmmm...
Transcript of Privilege Log
1
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
STEVEN POULOS,
Plaintiff,
vs. CASE NO.: 11-23833
ALLSTATE INSURANCE COMPANY,
RMK INSURANCE GROUP, INC. and
JOSE KUDJA, individually, and, REBECCA
KUDJA, individually
Defendants.
/
DEFENDANT, ALLSTATE INSURANCE COMPANY’S, PRIVILEGE LOG
Defendant, Allstate Insurance Company, files its privilege log regarding documents
requested in Plaintiff’s Second Request to Produce.
Document Description Privilege Asserted
Compliance review summaries prepared by Allstate compliance
analyst Joe Cackowski.
Work Product
Emails from Allstate compliance analyst Joe Cackowski to
Allstate’s Florida HR manager and Controller Department
supervisors regarding summaries of compliance reviews
Work Product
Emails from Allstate’s Florida HR manager to Corporate Security
regarding summaries of compliance reviews
Work Product
Letter from Allstate in-house counsel to Allstate Corporate
Security Department regarding opening investigation into the
RMK Insurance Agency
Attorney-Client &
Work Product
Correspondence (involving only Allstate employees) to and from
Corporate Security investigators regarding investigation of the
RMK Insurance Agency
Attorney-Client &
Work Product
Allstate CIP reports obtained by Corporate Security Department as
part of its investigation of the RMK Insurance Agency
Attorney-Client &
Work Product
Corporate Security’s video interviews with employees of the RMK
Insurance Agency as part of Corporate Security’s investigation of
the RMK Agency
Attorney-Client &
Work Product
Corporate Security’s audio interview with employee of the RMK
Insurance Agency as part of Corporate Security’s investigation of
the RMK Agency
Attorney-Client &
Work Product
2
Document Description Privilege Asserted
Email and letter from Corporate Security investigator to Allstate
in-house counsel regarding investigation of the RMK Insurance
Agency
Attorney-Client &
Work Product
Letter from Allstate in-house counsel to Allstate Florida Region
Field Vice President regarding Corporate Security’s investigation
of the RMK Insurance Agency and legal advice regarding same
Attorney-Client &
Work Product
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing has been furnished by e-mail to
Mark S. London, Esquire and Lisa J. London, Esquire at [email protected];
[email protected]; and [email protected], (Counsel for Plaintiff), and Sean L.
Collin and Philip M. Snyder at [email protected] and [email protected],
(Counsel for Defendants, RMK Insurance Group, Inc., n/k/a RMK Consulting Group, Jose Kudja
and Rebecca Kudja) this 31st day of October, 2013.
s/ Brett M. Carey
LORI J. CALDWELL
Florida Bar No. 0268674
E-mail: [email protected] (primary)
E-mail: [email protected] and
[email protected] (secondary)
BRETT M. CAREY
Florida Bar No. 0091355
E-mail: [email protected] (primary)
E-mail: [email protected] and
[email protected] (secondary)
RUMBERGER, KIRK & CALDWELL
A Professional Association
Lincoln Plaza, Suite 1400
300 South Orange Avenue (32801)
Post Office Box 1873
Orlando, Florida 32802-1873
Telephone: (407) 872-7300
Telecopier: (407) 841-2133
Attorneys for Defendant
