Geico claimed that Estilien and Hillman found that a party had to do a special show before the discovery of the opposing lawyer`s billing documents and that Paton failed to do such a show. Geico also claimed that materials were privileged and irrelevant. The fourth district granted the petition and quashed the orders of the district courts that controlled Estilian. Paton sought a review of the Fourth District Court of Appeal`s decision, saying it recalcitrated with State Farm &Fire Casualty Co. v. Palma, 555 so. 2d 836 (1990), a Florida Supreme Court case in which the court found that the opposing attorney`s accounting records are relevant to a litigation involving attorneys` fees with a success fee multiplier. In the years leading up to Paton, courts largely treated with intellectual curiosity issues of discovery and admissibility of an adversary`s billing documents, citing in part the state of Florida`s unexplained law.

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