FLORIDA FARM BUREAU GENERAL INSURANCE COMPANY v. NICHOLAS FRANK COPERTINO
27 Fla. L. Weekly D652 (Fla. 4th DCA Mar. 20, 2002)
The appellate court concluded that the facts in the instant case differed from Ruiz in that the documents were prepared during litigation where the issue of bad faith was raised. This was not a case where bad faith litigation was simply foreseeable-it was actually being litigated at the time the memoranda were made. Thus, the court granted the petition.