LONGWOOD, Florida June 3, 2021, Insurance Office of America, John Ritenour and Heath Ritenour are facing a Second Motion to Compel Production of Documents in defamation case they filed against former employees and their legal counsel. The following are direct quotes from the arguments made in the filed Motion and are a matter of public record. As of the time of this press release, there has been no hearing or determination by the Court as to the issues presented in the Motion.
The Motion states and alleges: “Once again Plaintiff Insurance Office of America has shirked its discovery obligations. On November 30, 2020, [Defendant] served his Second Request for Production of Documents on IOA, seeking to discover (sic) evidence underlying IOA’s 91- page complaint which alleges claims of defamation, tortious interference, and abuse of process…Exhibit A. On December 29, 2020 Insurance Office of America responded with boilerplate objections to each of Defendant’s narrowly tailored requests. Exhibit B. This is the second time that Plaintiff has completely failed to respond to [this Defendant’s] discovery requests. Insurance Office of America has completely failed to comply with Defendant’s requests for discovery in this matter.”
The Motion goes on to state and allege: “IOA’s blanket objections are inappropriate and should be overruled, particularly given the breadth of Plaintiffs’ 91- page complaint. Moreover, because this is a defamation case, discovery of the truth is fundamentally important as truth is a defense to IOA’s claims. IOA, by suing Defendant and others for defamation, has placed its own reputation and practices at front and center. Yet IOA has resisted producing any responsive discovery. IOA is essentially using its defamation claim as a “Weapon” to attack Defendant, but then is hiding behind a “shield” of claims of irrelevance and harassment to avoid providing discovery.”
The Motion further argues: “The Rules of Civil Procedure provide for liberal discovery and fundamental fairness dictates that Defendant be afforded a meaningful opportunity to discover IOA’s evidence underlying its serious claims, which Defendant maintains were filed in retaliation for Defendant first suing IOA.”
The Motion continues to argue and allege: “Defamation and tortious interference claims require evidence of actual damages, and IOA has refused to produce any evidence as to IOA’s claim for damages…Many of Defendant’s requests seek relevant discovery concerning an element of IOA’s claim. IOA should be compelled to produce such evidence.”
The Motion concludes by stating and alleging: “Fundamental fairness dictates that IOA comply with its discovery obligations and produce documents that bear on IOA’s own allegations. Defendant has a right to discover the factual basis for IOA’s allegations underlying IOA’s three claims against him. Sanofi–Synthelabo v. Apotex, Inc., 299 F.Supp.2d 303, 308–09 (S.D.N.Y.2004) (finding it unfair for complainant to assert contentions to the court and then to rely on privilege to block disclosure of materials that might disprove or undermine those contentions).”
This release is for informational purposes and to locate witnesses who have any information as to the reputations of Insurance Office of America, John Ritenour and/or Heath Ritenour relative to their own defamation lawsuit filed in Seminole County, Florida against former employees and their legal counsel. As of the date of this release, the Motion has not been heard or decided by the Court, the case has not gone to trial and there has been no determination on the merits of any claims.
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