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, OBJECTIONS TO NUMBERS 1 19 AND 33 40 OF PLAINTIFFS SECOND REQUEST TO PRODUCE The Defendant, Allstate Insurance Company, hereby responds to numbers 1 19 and 33 401 of Plaintiffs Second Request to Produce, dated May 1, 2013, as follows: REQUEST FOR PRODUCTION NO. 1: Any and all documents, correspondence, emails, notes, interoffice memoranda, intraoffice memoranda, etc. from January 1, 2010 through and including August 31, 2012, to Richard Cairns in regards to the KUDJA GROUP which advised Richard Cairns that the KUDJA GROUP had violated Section XVII.b.3 of the Exclusive Agency Agreement, to wit: The company may terminate the agency agreement with cause cause may include but is not limited to breach of this agreement, fraud, forgery, misrepresentation or conviction of a crime. A. This production should include, but not limited to, all correspondence between Richard Cairns and employees of ALLSTATE leading to the determination that the KUDJA GROUP AGENCY should be terminated. All lists of policies that were reviewed by ALLSTATE employees prior to or after the determination was made that the KUDJA GROUP had violated its agency agreement specifically including but not limited to the falsification of company document or other company related items. CASE NO.: 11-23833

B.

Allstate served responses to numbers 20 32 on July 5, 2013.

C.

Any notices, memoranda or other documentation to terminate, not renew or increase premiums relating to policies which were underwritten by the KUDJA GROUP. Said notices, memoranda or other documents include but are not limited to intraoffice memos, letters and/or notices to policy holders and notices and/or warnings that were sent by ALLSTATE to the KUDJA GROUP. Any audits performed by ALLSTATE regarding the KUDJA GROUPs policies. Any investigations made by ALLSTATE (documents, reports, notes, emails, etc.) providing Richard Cairns the underlying information of the KUDJA GROUPs violation of the agency agreement.

D. E.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 2: Any and all documents, correspondence, emails, notes, interoffice memoranda, intraoffice memoranda, etc. from January 1, 2010 through and including August 31, 2012, between ALLSTATE and KUDJA GROUP advising the KUDJA GROUP: A. Policies which were written had irregularities including but not limited to issues raised by underwriting, rejection of policies by underwriting and/or request for clarification regarding issues in the policy by underwriting, specifically including but not limited to the policies identified in paragraph 1.B. above. Which policies were the basis for the termination of the agency agreement on August 4, 2010. Providing the KUDJA GROUP warning(s) to the KUDJA GROUP regarding policies being written as improper, fraudulent, or with questionable underwriting guidelines. Of an audit and its findings regarding the policies written by KUDJA GROUP.

B.

C.

D.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 3: Any and all internal memoranda, interoffice memoranda and/or intraoffice memoranda, emails by and between Richard Cairns, Nidia Pita, Janice Brown-Francois, Debra Shea, Mike Sheely regarding the sale of the economic interest in the book of business in the KUDJA GROUP from July 1, 2010 through and including December 31, 2010. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 4: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from Richard S. Cairns to the KUDJA GROUP between August 4, 2010 and October 1, 2010, regarding the sale of the economic interest in the KUDJA GROUPs book of business including, but not limited to, any emails from the KUDJA GROUP requesting ALLSTATE sell their book of business or any solicitations by Richard S. Cairns to sell their book of business.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 5: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from Debra Shea, Richard Cairns, Laura Kaplan to, or from, the KUDJA GROUP between August 1, 2010 and October 30, 2010, providing information that the economic interest in the book of business of the KUDJA GROUP is for sale, and what, if any information is to be provided to prospective agents regarding the agency as a viable business, including whether any information should be provided to the prospective buyer that the agency was closed and the reasons the agency was closed. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 6: Any and all documents, pamphlets, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. between December 1, 2009 through and including December 31, 2010, regarding the method ALLSTATE utilizes to determine bonuses for the territory defined as the State of Florida and for salaried employees of ALLSTATE in the State of Florida.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 7: Any and all documents, pamphlets, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. between December 1, 2009 through and including December 31, 2010 which establish the method ALLSTATE utilizes to determine whether a territory defined as the State of Florida and for salaried employees of ALLSTATE has reached its sales goals and what the sales goals were, including but not limited to any hiring quotas, policy/premium retention quotas issued by ALLSTATE. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 8: Any and all documents, pamphlets, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. between December 1, 2009 through and including December 31, 2010 which defines what occurs to an agencys economic interest in its book of business if the book of business is repurchased by ALLSTATEs corporate entity, defining whether the sales and premiums from said book of business is considered as part of the territory defined as the State of Florida reaching its sales goals and/or goals necessary for bonuses to be paid to the salaried employees of the territory. The documents shall also include 5

but not be limited to any financial affect the sale of the economic book of business back to the corporate entity may have on the State of Florida territorys budget. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 9: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from Laura Kaplan regarding her lunch meeting with Plaintiff, STEVEN POULOS, between August 1, 2010 and September 1, 2010 including, but not limited to, Laura Kaplans calendar for the month of August reflecting any meetings with Steve Poulos or the KUDJA GROUP and any notes or memoranda relating to said meeting(s). RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 10: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. to, or from, Debra Shea from August 1, 2010 through December 31, 2010, including but not limited to correspondence, to or from, Steven Poulos, Janice Brown-Francois, Richard S. Cairns, Nidia Pita, Laura Kaplan regarding the Plaintiffs inquiry about the KUDJA GROUPs closed agency status and the reason for same. Said documents shall include any notices, emails, documents or otherwise Debra Shea received 6

including the documents reflecting that RMK INSURANCE GROUP was terminated for falsification of company documents or any other basis for termination of the KUDJA GROUP. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 11: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. between August 1, 2010 and December 31, 2010 from Richard S. Cairns to Debra Shea, Laura Kaplan, Nidia Pita, Janice Brown-Francois or from Debra Shea, Laura Kaplan, Nidia Pita, Janice Brown-Francois or Debra Shea to Richard Cairns regarding what information the Plaintiff was to be provided regarding the KUDJA GROUP including, but not limited to: A. B. C. The reasons the agency was closed. Whether that information was to be withheld. What policies, if any, were to be terminated. improperly written. What policies if any were

D. E. F.

The losses the business would suffer as a result of the policies being falsified. What communication, if any, should be made with the KUDJA GROUP. Which employees should contact the KUDJA GROUP (any documents memoranda codifying the conversation with the KUDJA GROUP). What agencies would be servicing the KUDJA GROUP policies. What information, if any, should be provided regarding the servicing of the KUDJA GROUP policies.

G. H.

I.

What information, if any, should be provided regarding the servicing of the KUDJA GROUP customer including, but not limited to, sales of additional insurance needed by said customers. Any emails to Richard S. Cairns regarding the pending agreement with Plaintiff. What documents, if any, were requested by Plaintiff. What responses/documents, if any, were provided to Plaintiff. What requests, if any, were made to the KUDJA GROUP regarding the production of documents to Plaintiff including whether ALLSTATE requested permission to advise Plaintiff of the reasons that the KUDJA GROUPs agency was terminated. What the KUDJA GROUP advised ALLSTATE the Plaintiff was told as the reason for the agency termination. Defining what explanation(s) was to be given to the KUDJA GROUP customers/policyholders who prepared the memorandum as to what was to be told to the KUDJA GROUP customers/policyholders. What, if any, written documentation was forwarded to the KUDJA GROUP customers/policyholders.

J. K. L. M.

N.

O.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 12: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from August 1, 2010 through December 31, 2010, from the KUDJA GROUP to Richard S. Cairns, Debra Shea, Laura Kaplan, Nidia Pita, Janice BrownFrancois and Mike Sheely regarding agents in the geographic location servicing the KUDJA GROUPs customers.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 13: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. to or from Mike Sheely from August 1, 2010 through and including December 31, 2010 regarding the KUDJA GROUP customers and/or policyholders and a determination of who will be providing service to said customers and/or policyholders. Said documents should include what information, if any, the Plaintiff was to be told regarding the servicing of the KUDJA GROUP policyholders and customers. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 14: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from December 1, 2009 through December 31, 2010 regarding ALLSTATEs policies in regard to the servicing a book of business (policyholders for an agency which has been terminated i.e. whether said policyholders/customers are to contact the ALLSTATE 800 telephone number, whether they are directed to other agencies in the geographic area, what the written policies of ALLSTATE during the year 2010 that ALLSTATE had regarding these circumstances. 9

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 15: Any and all documents correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from August 4, 2010 through and including December 31, 2010 to the KUDJA GROUP from ALLSTATE regarding the servicing of the KUDJA GROUPs customers including, but not limited to: whether the KUDJA GROUP could select another agency, or more than one agency, to service their policyholders and whether any of the policyholders were being terminated/audited and/or subject to premium increases. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 16: Any and all documents correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from August 4, 2010 through and including December 31, 2010, from the KUDJA GROUP to ALLSTATE regarding the servicing of the KUDJA GROUPs customers including, but not limited to: whether the KUDJA GROUP could select another agency, or more than one agency, to service their policyholders and whether any of the policyholders were being terminated.

10

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 17: Any and all documents correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from August 4, 2010 through and including December 31, 2010 of any termination notices to policyholders/customers of the KUDJA GROUP. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 18: Any and all documents correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. which provide an itemized list of the existing policies of the KUDJA GROUP on August 1, 2010. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. 11

Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 19: Any and all documents correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. which reflect which of said insurance policies of the KUDJA GROUP which ALLSTATE had determined to contain false information and what, if any, disposition was made by ALLSTATE employees during the period of July 1, 2010 through December 31, 2010 regarding said policies i.e. to terminate said policy, to increase the rate of the policy, to require the customer to provide further documentation, etc. Said documents shall further include any correspondence to the policyholder. A. The documents should include but not be limited to what affect the false information had on the rate(s) subsequently offered to the customers/policyholders. The number of Castle Key Homeowner HO3 policies that were issued by the KUDJA GROUP on July 1, 2010 and the number of Castle Key HO3 policies ordered for resinspection by ALLSTATE between July 1, 2010 and February 1, 2011. The number of policies that received premium increases and/or were not renewed from July 1, 2010 through and including March 31, 2011.

B.

C.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 33: Any and all documents correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. and/or policies or pamphlets issued by ALLSTATE from December 1, 2009 through and including December 31, 2010 regarding: 12

A.

The sale of agency which has been terminated for cause which provide limitations on ALLSTATEs employees requirements to act as a sales agent for an agency wishing to sell its book of business such as business brokerage forms, etc. Any policy prohibiting ALLSTATE employees from selling a terminated agencys economic interest in the book of business. Any directives to ALLSTATEs employees as to what its employees are, or are not, to provide regarding the sale of a terminated agencys book of business. Statement or policy provided to ALLSTATEs employees regarding what they are permitted to say, what information they are permitted to provide, what active interest they may take in the sale of a terminated agencys book of business.

B.

C.

D.

RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 34: Any and all requests to ALLSTATE employees, territorial sales leaders or officers regarding what information could be released to Plaintiff on the KUDJA GROUP by: A. B. C. D. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead 13 Debra Shea Laura Kaplan Janice Brown-Francois Nidia Pita

to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 35: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. to Plaintiff regarding his attendance at the ALLSTATE training, ALLSTATE Education Program and such other required training from September 1, 2010 through December 31, 2010 from: A. B. C. D. E. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or Debra Shea Laura Kaplan Janice Brown-Francois Nidia Pita Richard S. Cairns

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 36: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from Richard S. Cairns to Plaintiff regarding meetings that he had with Plaintiff specifically including, but not limited to, any discussions Richard S. Cairns had with Plaintiff regarding: A. The reasons that KUDJA GROUP was terminated. 14

B.

The servicing of the KUDJA GROUP customers including, but not limited to, sales of additional insurance needed by said customers. Where the premium or policies for said sales would go.

C. RESPONSE:

Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 37: Any and all documents correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. from Richard S. Cairns to Debra Shea, Laura Kaplan, Nidia Pita, Janice Brown-Francois regarding meetings that he had with Plaintiff specifically including, but not limited to, any discussions Richard S. Cairns had with Plaintiff regarding: A. B. The reasons that KUDJA GROUP was terminated. The servicing of the KUDJA GROUP customers including, but not limited to, sales of additional insurance needed by said customers. Where the premium or policies for said sales would go.

C. RESPONSE:

Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. 15

REQUEST FOR PRODUCTION NO. 38: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. reflecting the delivery by ALLSTATE to Plaintiff of policies transferred by the KUDJA GROUP to Plaintiff between January 1, 2011 and April 30, 2011. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 39: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. to Plaintiff between January 1, 2011 through and including March 31, 2012 reflecting the customer policies of KUDJA GROUP who received an increase of premium in excess of 5% or a letter of termination and any documents relating to the increase in premium and/or termination of the policy. Said document should include but not be limited to: A. B. C. D. Discrepancies between the garaging of the automobile and the mailing address. Commercial policies without a business name as named insured. Customer credit check resulting in a no hit. The ratio of 10/20 policies contained in the KUDJA GROUP book being transferred versus the average economic book of ALLSTATE INSURANCE agents in Florida. T-docs report.

E. RESPONSE:

Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead 16

to the discovery of admissible evidence, confidential, proprietary, work product and privileged. Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. REQUEST FOR PRODUCTION NO. 40: Any and all documents, correspondence, letters, emails, internal memoranda, interoffice memoranda, intraoffice memoranda, etc. which provide the current address and telephone number for: A. B. C. D. E. F. G. H. I. J. L. M. RESPONSE: Allstate objects to this request on the grounds that it is vague, ambiguous, overbroad, unduly burdensome, and seeks documents which are irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, confidential, proprietary, work product and privileged. 17 Mariano Reis Richard S. Cairns Kaylee Covard Nidia Pita Janice Brown-Francois Debra Shea Laura Kaplan Olga Otero-Brown Jan Buswell Bob Jackson [sic] Mary Lott Joe Cackowski

Allstate is still reviewing and searching for documents and will produce non-objectionable responsive documents it discovers to Plaintiff. Allstate reserves the right to amend or

supplement these objections based on its review of any documents. 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 filings@thelondonlawfirm.com; mark@thelondonlawfirm.com; and gtrglfr@gmail.com, (Counsel for Plaintiff), and Sean L. Collin and Philip M. Snyder at family_civil@lyonssnyder.com and sean@lyonssnyder.com, (Counsel for Defendants, RMK Insurance Group, Inc., n/k/a RMK Consulting Group, Jose Kudja and Rebecca Kudja) this 31st day of July, 2013.

s/ Brett M. Carey LORI J. CALDWELL Florida Bar No. 0268674 E-mail: lcaldwell@rumberger.com (primary) E-mail: docketingorlando@rumberger.com and lcaldwellsecy@rumberger.com (secondary) BRETT M. CAREY Florida Bar No. 0091355 E-mail: bcarey@rumberger.com (primary) E-mail: docketingorlando@rumberger.com and bcareysecy@rumberger.com (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

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