On the jurisdictional issue, Deininger has apparently figured out that the amount in dispute is over $75,000 (?!) so that the appropriate jurisdiction is federal court.
Barisone is suing three insurance companies. The attorneys for Great American liased with the counsel for the other two, and reported that one of the other two, American National Insurance Company, had not issued insurance to either Barisone or SGF, and therefore couldn’t provide the insurance policy in discovery. Deininger did not address that assertion in his letter.
ETA. Somehow I was not exactly shocked to learn that Barisone/Deininger were suing an insurance company that had not issued a policy. That particular defendant should have a pretty easy time of it.