Mondamin Wilkins v. Progressive Select Insurance Company, Case No. 8:24-cv-1793-TPB-AAS (U.S. Middle District of Florida, Aug 28, 2025 – Judge Amanda Arnold Sansone)

(Order granting in part Progressive Select Insurance Company’s Motion to Compel, holding that Progressive demonstrated a substantial need under Rule 26(b)(3)(A) and could not obtain their substantial equivalent without undue hardship. The Court reasoned that, although protected by the work product doctrine, these documents were discoverable in a statutory bad faith action because they directly relate to the realistic possibility of settlement within policy limits.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-01793-54-8-cv