Privilege Log

Investigation correspondence as well as audio/video interview of RMK Employee withheld. Was this even reported to the Florida Department of Insurance? Hmmm...

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Privilege Log

Investigation correspondence as well as audio/video interview of RMK Employee withheld. Was this even reported to the Florida Department of Insurance? Hmmm...

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA STEVEN POULOS, Plaintiff,

vs. ALLSTATE INSURANCE COMPANY, RMK INSURANCE GROUP, INC. and JOSE KUDJA, individually, and, REBECCA KUDJA, individually Defendants. / DEFENDANT, ALLSTATE INSURANCE COMPANYS, PRIVILEGE LOG Defendant, Allstate Insurance Company, files its privilege log regarding documents requested in Plaintiffs Second Request to Produce. Document Description Compliance review summaries prepared by Allstate compliance analyst Joe Cackowski. Emails from Allstate compliance analyst Joe Cackowski to Allstates Florida HR manager and Controller Department supervisors regarding summaries of compliance reviews Emails from Allstates Florida HR manager to Corporate Security regarding summaries of compliance reviews Letter from Allstate in-house counsel to Allstate Corporate Security Department regarding opening investigation into the RMK Insurance Agency Correspondence (involving only Allstate employees) to and from Corporate Security investigators regarding investigation of the RMK Insurance Agency Allstate CIP reports obtained by Corporate Security Department as part of its investigation of the RMK Insurance Agency Corporate Securitys video interviews with employees of the RMK Insurance Agency as part of Corporate Securitys investigation of the RMK Agency Corporate Securitys audio interview with employee of the RMK Insurance Agency as part of Corporate Securitys investigation of the RMK Agency Privilege Asserted Work Product Work Product CASE NO.: 11-23833

Work Product Attorney-Client & Work Product Attorney-Client & Work Product Attorney-Client & Work Product Attorney-Client & Work Product Attorney-Client & Work Product

Document Description Email and letter from Corporate Security investigator to Allstate in-house counsel regarding investigation of the RMK Insurance Agency Letter from Allstate in-house counsel to Allstate Florida Region Field Vice President regarding Corporate Securitys investigation of the RMK Insurance Agency and legal advice regarding same CERTIFICATE OF SERVICE

Privilege Asserted Attorney-Client & Work Product Attorney-Client & Work Product

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