ERNEST JONES AND DOMINICA JONES NO. 24-C-488 VERSUS FIFTH CIRCUIT ALEXANDER STAG AND PRIVILEGE COURT OF APPEAL UNDERWRITERS RECIPROCAL EXCHANGE STATE OF LOUISIANA

January 28, 2025 Linda Wiseman First Deputy Clerk

IN RE ALEXANDER STAG AND PRIVILEGE UNDERWRITERS RECIPROCAL EXCHANGE APPLYING FOR SUPERVISORY WRIT FROM THE FORTIETH JUDICIAL DISTRICT COURT, PARISH OF ST JOHN THE BAPTIST, STATE OF LOUISIANA, DIRECTED TO THE HONORABLE VERCELL FIFFIE, DIVISION "A", NUMBER 81,513

Panel composed of Judges Jude G. Gravois, Marc E. Johnson, and John J. Molaison, Jr.

WRIT DENIED Relators, Alexander Stag and Privilege Underwriters Reciprocal Exchange (“PURE”), seek review of the trial court’s September 26, 2024 judgment that granted the motion to compel the corporate deposition of PURE, filed by Respondents, Ernest and Dominica Jones, and denied Relators’ motion for protective order. They argue that allowance of the corporate deposition to proceed is a direct contraction of the purely procedural purpose of the Louisiana Direct Action Statute, La. R.S.

22:1269, is unduly burdensome and harassing, and will force it to disgorge information, including litigation strategy, privileged information and internal claims handling information that is of no significance. They further argue that Respondents’ discovery requests unabashedly seeks information that is protected by privilege and/or reflects the mental impression of counsel, seeks the premature disgorgement of the defense’s witnesses and exhibits, and seeks information that is not relevant. They contend that a protective order must be issued to prevent an abuse of the discovery process by Respondents.

In ruling on discovery matters, the trial court is vested with broad discretion, and an appellate court should not disturb such rulings absent a clear abuse of discretion. Danos v. Minnard, 19-268 (La. App. 5 Cir. 8/28/19), 279 So.3d 486, 490.

Upon review, on the showing made, we find no clear abuse of discretion by the trial court, nor a sufficient basis upon which to disturb the trial court’s rulings.

Accordingly, the writ application is denied.

Gretna, Louisiana, this 28th day of January, 2025.

MEJ JGG JJM SUSAN M. CHEHARDY CURTIS B. PURSELL CHIEF JUDGE CLERK OF COURT

SUSAN S. BUCHHOLZ FREDERICKA H. WICKER CHIEF DEPUTY CLERK JUDE G. GRAVOIS MARC E. JOHNSON STEPHEN J. WINDHORST LINDA M. WISEMAN JOHN J. MOLAISON, JR. FIRST DEPUTY CLERK SCOTT U. SCHLEGEL TIMOTHY S. MARCEL FIFTH CIRCUIT MELISSA C. LEDET JUDGES 101 DERBIGNY STREET (70053) DIRECTOR OF CENTRAL STAFF POST OFFICE BOX 489 GRETNA, LOUISIANA 70054 (504) 376-1400 (504) 376-1498 FAX www.fifthcircuit.org

NOTICE OF DISPOSITION CERTIFICATE OF DELIVERY I CERTIFY THAT A COPY OF THE DISPOSITION IN THE FOREGOING MATTER HAS BEEN TRANSMITTED IN ACCORDANCE WITH UNIFORM RULES - COURT OF APPEAL, RULE 4-6 THIS DAY 01/28/2025 TO THE TRIAL JUDGE, THE TRIAL COURT CLERK OF COURT, AND AT LEAST ONE OF THE COUNSEL OF RECORD FOR EACH PARTY, AND TO EACH PARTY NOT REPRESENTED BY COUNSEL, AS LISTED BELOW:

24-C-488 E-NOTIFIED 40th District Court (Clerk) Honorable Vercell Fiffie (DISTRICT JUDGE) Tori S. Bowling (Relator) MAILED Gilbert V. Andry, IV (Respondent) Sydnee D. Menou (Relator) Attorney at Law Brandi A. Barze (Relator) Baronne Street Attorneys at Law New Orleans, LA 70113 Post Office Box 1151 Baton Rouge, LA 70821