Genovese v. Provident Life and Accident Ins. Co., 2011 Fla. LEXIS 621 (2011)

Attorney-client privileged communications are not discoverable in first-party bad faith actions.

The goal of the attorney-client privilege is to encourage full and frank communication between an attorney and his client. While work-product materials pertaining to coverage, benefits, liability, or damages are discoverable in first-party bad faith actions, attorney-client privileged communications are not discoverable in such actions because such disclosure would severely hamper the intended goal of the privilege.

Case Law Alert - 3rd Qtr 2011