There hasn’t been much good news from Florida lately, particularly in the area of bad faith litigation. In a rare bright note, however, the Florida Supreme Court has declared that the liberal rules that it adopted a few years ago requiring disclosure of work product in first party bad faith cases does not apply with respect to attorney-client privileged communications.
In Allstate Indemnity Co. v. Ruiz, 899 So.2d 1121 (Fla. 2005