Discovery in insurance coverage actions in Florida is often hotly litigated. Despite the prevalence of discovery disputes, case law has often failed to provide much uniform guidance to practitioners around the state. Indeed, Florida state and federal court decisions seem to conflict on several aspects of insurance-related discovery, as do the various district courts of appeal. For example, compare State Farm Fire & Casualty v. Valido, 662 So. 2d 1012, 1013 (Fla. 3d DCA App. 1995) (quashing order requiring production of State Farm's claim files, manuals, guidelines and documents in a first party coverage dispute, finding documents irrelevant to dispute) and Homeowners Choice Property & Casualty Insurance v. Mahady, 284 So. 3d 582, 583 (Fla. 4th DCA 2019) (quashing order allowing discovery of claim files and underwriting files in coverage dispute because "insurer's liability for coverage and the amount of the policy owners' damages have not been finally determined") with American Home Assurance v. Vreeland, 973 So. 2d 668, 672 (Fla. 2d DCA. 2008) (allowing limited discovery of underwriting file relevant to whether a party was an insured).