BANK OF AMERICA, N.A.
v.
BCML HOLDING, LLC

Fla. 3d DCA | 2021-05-26
No. 20-1630
299 So. 3d 430 Florida District Court of Appeal, Third District (2021) Positive Treatment
Cited by 5 cases

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Holding

Discovery orders must be limited to matters relevant to the litigation as framed by the parties' pleadings, and a trial court abuses its discretion by ordering discovery of unrelated materials.


Headnotes

[1] Discovery must be limited to matters relevant to the litigation as framed by the parties' pleadings, and a trial court abuses its discretion by ordering discovery of unre…

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Key Quotes

“Discovery is limited to those matters relevant to the litigation as framed by the parties' pleadings.”

Court citing Rousso v. Hannon, 146 So. 3d 66, 69 (Fla. 3d DCA 2014)

Facts & Procedural History

Bank of America sought certiorari review of a trial court order requiring production of specific discovery materials in litigation against BCML Holdin…

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Opinion of the Court

Opinion filed May 26, 2021. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D20-1630 Lower Tribunal No. 16-19168

________________

Bank of America, N.A.,

Petitioner,

vs.

BCML Holding, LLC, et al., Respondents.

A Writ of Certiorari to the Circuit Court for Miami-Dade County, William Thomas, Judge. Liebler, Gonzalez & Portuondo, and Adam J. Wick, for petitioner. Jacobs Legal, PLLC, and Bruce Jacobs; Wesoloski Carlson, P.A., and Erik D. Wesoloski, for respondents. Before HENDON, GORDO and BOKOR, JJ. HENDON, J. Upon consideration, we grant Bank of America’s Petition for Writ of Certiorari, and quash the trial court’s November 3, 2020, order with respect to the specific discovery materials that are the subject of this petition.1 See Bank of New York Mellon v. Figueroa, 299 So. 3d 430 (Fla. 3d DCA 2019) (quashing a trial court’s order allowing discovery of unrelated loans and lawsuits); Rousso v. Hannon, 146 So. 3d 66, 69 (Fla. 3d DCA 2014) (“Discovery is limited to those matters relevant to the litigation as framed by the parties' pleadings.”).

Petition for Writ of Certiorari granted, order quashed.

Footnotes
1 Specific Areas of Inquiry 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, and 13; Duces Tecum Requests 2, 3, 4, 5, 6, 7, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, and 19.

Cases With Similar Vibessemantic neighbors from the corpus


Citator

Cited By

  • Bank of Am., N.A. v. Bcml Holding, LLC, 299 So. 3d 430 (Fla. 3d DCA 2021)
    …ration, we grant Bank of America’s Petition for Writ of Certiorari, and quash the trial court’s November 3, 2020, order with respect to the specific discovery materials that are the subject of this petition.1 See Bank of New York Mellon v. Figueroa, 299 So. 3d 430 (Fla. 3d DCA 2019) (quashing a trial court’s order allowing discovery of unrelated loans and lawsuits); Rousso v. Hannon, 146 So. 3d 66, 69 (Fla. 3d DCA 2014) (“Discovery is limited to those matters relevant to the litigation as framed by the partie…
  • …hat are the subject of this petition, the trial court’s order denying in part Bank of America’s motion for protective order departs from the essential requirements of the law, thereby causing irreparable injury. See Bank of N.Y. Mellon v. Figueroa, 299 So. 3d 430 (Fla. 3d DCA 2019); Rousso v. Hannon, 146 So. 3d 66 (Fla. 3d DCA 2014); see also Bank of Am., N.A. v. BCML Holding, LLC, 319 So. 3d 786 (Fla. 3d DCA 2021). Therefore, we grant the petition for writ of certiorari and quash the order. Petition grante…
  • …the discovery order was a departure from the essential requirements of law resulting in a material injury that will affect the remainder of the proceedings below and the injury cannot be corrected on appeal.” Bank of New York Mellon v. Figueroa, 299 So. 3d 430, 433 (Fla. 3d DCA 2019) (citing Allstate Ins. Co. V. Langston, 655 So. 2d 91, 94-95)). Petitioner meets this standard 3 of irreparable harm as the production of work product protected materials constitutes impermissible “cat out of the bag” p…

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