GRIFFIN, J.
Petitioner, Vesta Fire Insurance Corporation ["Vesta"], the defendant below, seeks a writ of certiorari to quash an order of the trial court requiring Vesta to produce inter alia, its "entire claim file" to the plaintiff below, Gladys Figueroa ["Figueroa"]. We agree that the order should be quashed.
Figueroa's complaint against Vesta alleges that she suffered a covered loss under her policy with Vesta consisting of damage to her 1995 Peterbilt truck due to an unknown third party's acts of theft and vandalism. Count I of her complaint alleges Vesta's breach of the insurance contract and count II alleges bad faith. With the filing of the complaint, Figueroa served a request for production of various documents including Vesta's entire claim file. Figueroa also subpoenaed the claim file of Vesta's independent adjustor, Gator Adjustors, Inc. ["Gator"]. In response, Vesta timely objected on the basis of work product and attorney/client privilege. After a hearing on Figueroa's motion to compel, the trial court reserved ruling pending Figueroa's "compliance with the pertinent Florida Rule of Civil Procedure" regarding discovery of material that "may be protected by the work product privilege." Apparently, this referred to the provision in Florida Rule of Civil Procedure 1.280(b)(3), allowing discovery of work product where the requesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship.
Counsel for Figueroa filed with the trial court an affidavit averring the need for the claim file:
5. Long before this lawsuit was filed, Defendant retained Gator Adjuster's, Inc., as an independent adjuster to adjust Plaintiffs claim for policy benefits.
6. Gator Adjusters, Inc., assumed primary responsibility for adjusting plaintiffs claim, but did so in consultation with Defendant.
7. Plaintiff has requested a copy of the claim file of Gator Adjustors, Inc., including any documentary evidence of communications between Gator Adjuster's, Inc., and Defendant's representatives. Plaintiff requested this information through a subpoena directed to Gator Adjusters, Inc.
8. Plaintiff also requested the production of the above information directly from Defendant. Defendant objected to that discovery request, invoking the work product privilege.
9. Plaintiff needs the above-described information to prepare this case for trial.
10. The requested information contains a blow-by-blow diary of the insurer's investigation and decision-making progress with regard to Plaintiff's property insurance claim.
11. A cause of action for bad faith misconduct by an insurance company arises when a carrier intentionally denies, fails to process, or fails to pay a claim on a timely basis without a reasonable basis for such action. See Section 624.15, Fla. Stat.
12. The information sought to be discovered by Plaintiff explains how Defendant processed and considered her claim and why it rejected the claim. Therefore, the information is certainly relevant to the issues raised by the pleadings. Bad faith actions against an insurance company can only be proved by showing exactly how the company processed the claim, how thoroughly it was considered and why the company took the actions it did.
13. The claims file, as well as the documentary evidence of communications between Defendant's representatives and the independent adjuster hired by the Defendant is a unique, contemporaneously prepared history of Defendant's handling of Plaintiff's disputed claim. In an action such as this one, the need for information requested by Plaintiff is not only substantial, but overwhelming.
14. The substantial equivalent of the items requested by Plaintiff cannot be obtained through other means of discovery.
Subsequently, a second hearing was conducted on Figueroa's motion to compel discovery. At this hearing, the trial court, in reviewing the above-quoted affidavit, remarked: "Of course in these bad faith cases it's apparently very easy to make the showing because all you have to do is say what it says in the Brown case and really you have grounds for the showing." The case referred to by the trial court was Brown v. Superior Court, 137 Ariz. 327, 670 P.2d 725 (1983), a case in which the Arizona court required production of an insurer's claim file because it represented a "unique" history of the handling of the claim:
Brown's action alleged bad faith on the part of the insurance company by failing to pay Brown's claim for loss of earnings. Continental conceded at oral argument that the claims file contains a "blow-by-blow" diary of the insurer's investigation and decision-making process with regard to Brown's loss of earnings claim. The tort of bad faith arises when an insurance company intentionally denies, fails to process, or fails to pay a claim without a reasonable basis for such action. No matter how the test is defined, bad faith is a question of reasonableness under the circumstances. The portions of the claims file which explained how the company processed and considered Brown's claim and why it rejected the claim are certainly relevant to these issues.
Further, bad-faith actions against an insurer, like actions by client against attorney, patient against doctor, can only be proved by showing exactly how the company processed the claim, how thoroughly it was considered and why the company took the action it did. The claims file is a unique, contemporaneously prepared history of the company's handling of the claim; in an action such as this the need for the information in the file is not only substantial, but overwhelming. The "substantial equivalent" of this material cannot be obtained through other means of discovery.
670 P.2d at 734 (citations omitted).
Counsel for petitioner responded that, Brown notwithstanding, under this court's opinion in National Security Fire and Casualty Co. v. Dunn, 751 So.2d 777 (Fla. 5th DCA 2000), Figueroa should be required not only to show "need" but also to demonstrate an effort to obtain the substantial equivalent by means other than obtaining the work product of the carrier. Counsel for Figueroa replied:
Your honor, in this footnote in Dunn, this entire Dunn opinion is the
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