IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 22-23170-CIV-ALTONAGA/Damian

CARDINAL POINT, LLC; et al., 

Plaintiffs, 

v. 

EDGEWOOD PARTNERS INSURANCE 

CENTER, INC.; et al., 

Defendants. 

_____________________________________/

ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFFS’ 

DISCOVERY MEMORANDUM TO COMPEL PRODUCTION OF DOCUMENTS 

REQUESTED IN PLAINTIFFS’ SECOND REQUEST FOR PRODUCTION

THIS CAUSE came before the Court for a hearing on July 25, 2023, on Plaintiffs’ 

Discovery Memorandum to Compel Production of Documents Requested in Plaintiffs’ Second 

Request for Production (the “Memorandum”) [ECF No. 37] and Plaintiffs’ ore tenus Motion to 

Compel Production [ECF No. 57]. This matter is before the undersigned pursuant to an Order 

referring all discovery matters by Chief United States District Judge Cecilia M. Altonaga. [ECF 

No. 15].

THE COURT has reviewed the ore tenus Motion, the Memorandum, Defendants’ 

Response [ECF No. 40], and the pertinent portions of the record and is otherwise fully advised 

in the premises. The Court also heard oral argument from counsel for the parties who appeared 

before the undersigned on July 25, 2023. 

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During the July 25, 2023 hearing, the parties informed the Court they had reached an 

agreement regarding Document Request Nos. 2.15 and 2.35 prior to the hearing. As to the 

remaining disputes, it is hereby

ORDERED and ADJUDGED that Plaintiffs’ ore tenus Motion and Memorandum are

GRANTED IN PART AND DENIED IN PART as follows:

1. Defendants’ objection to the timeliness of Plaintiffs’ Memorandum is 

overruled.

2. Document Request Nos. 2.1, 2.3, 2.5, and 2.7: Defendants’ relevancy 

objection is sustained in part. Defendants’ other objections are overruled. Defendants 

shall produce the employment and compensation agreements sought in Document 

Request Nos. 2.1, 2.3, 2.5, and 2.7 if the agreements contain incentives relating to current 

or future business health plan reinsurance and stop loss business. If none of the requested 

agreements contain such incentives, Defendants need not produce the requested 

agreements and shall amend their responses to Document Request Nos. 2.1, 2.3, 2.5, and 

2.7 to state that no responsive documents exist containing incentives relating to current 

or future business health plan reinsurance and stop loss business.

3. Document Request Nos. 2.2, 2.4, 2.6, and 2.8: Defendants’ relevancy 

objection is sustained in part. Defendants’ other objections are overruled. Defendants 

shall produce communications relating to potentially or actually incentivizing Peter 

Robinson, Elisabeth Staggs, Caleb Chung, and Raj Gulati for current or future health 

plan reinsurance and stop loss business. If no such communications exist, Defendants 

shall amend their responses to Document Request Nos. 2.2, 2.4, 2.6, and 2.8 to state no

communications exist relating to potentially or actually incentivizing Peter Robinson, 

Case 1:22-cv-23170-CMA Document 61 Entered on FLSD Docket 08/03/2023 Page 2 of 4
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Elisabeth Staggs, Caleb Chung, and/or Raj Gulati for current or future health plan 

reinsurance and stop loss business.

4. Document Request No. 2.51: Defendants’ objections are overruled. 

Defendants shall confirm that all communications responsive to Document Request No. 

2.51 have been produced, and assuming all such communications have been produced, 

Defendants shall amend their response to state so. 

5. Document Request No. 2.52: Defendants’ objections are overruled. 

Defendants shall provide a chart showing new business by client for EPIC Re/Integro 

Re for 2023 as Defendants did for 2019-2022 in Bates-stamped document EPIC008734. 

In addition, Defendants shall provide Plaintiffs with documents sufficient to show new,

existing, and renewed business by client credited to EPIC Re/Integro Re for 2019 

through 2023. 

6. Document Request No. 2.24: Defendants’ relevancy objection is sustained 

in part. Defendants’ other objections are overruled. Defendants shall produce all portions 

of Board meeting minutes between January 2020 and February 2023 relating to 

potentially or actually incentivizing anyone other than Plaintiffs for current or future 

health plan reinsurance and stop loss business. In addition, to the extent Bates-stamped 

document EPIC007342 contains information regarding Peter Robinson or Blake Kirk, 

Defendants shall reproduce EPIC007342 with such information unredacted. 

7. Document Request No. 2.25: Defendants shall supplement their response 

to Document Request No. 2.25 to state that the July 28, 2021 Board meeting minutes 

contain no reference to Plaintiffs, and, therefore, no responsive documents exist. 

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8. Document Request No. 2.60: Defendants’ objections are overruled as the 

Court finds that the requested tax forms are directly relevant to the issues in this case. 

Defendants shall produce the requested tax forms. 

9. Defendants shall comply with this Order by August 4, 2023. 

Although this written Order is entered this 2nd day of August, 2023, the Court set forth 

its rulings at the July 25, 2023 hearing, and, therefore, these rulings are effective as of that 

date.

DONE AND ORDERED in Chambers at Miami, Florida, this 2nd day of August, 2023.

________________________________________

MELISSA DAMIAN 

UNITED STATES MAGISTRATE JUDGE

Copies provided to:

All Counsel of Record

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