News & Analysis as of

Discovery Attorney-Client Privilege Insurance Litigation

Zelle  LLP

Balancing Discovery and Protecting the Attorney-Client Privilege In the Insurance Coverage Context

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A recent case out of Colorado highlights the continued attack on the attorney-client privilege during the claim adjustment process. In In re: Hill Hotel Owner, LLC v. Hanover Insurance Company, 557 P.3d 798 (Colo. Oct. 29,...more

Carlton Fields

District of Illinois Directs Insurer to Supplement Record to Support Privilege Based on “Common Interest Doctrine”

Carlton Fields on

In Ansur America Insurance Co. v. Borland, the U.S. District Court for the Southern District of Illinois addressed a discovery dispute involving claims brought by Ansur America Insurance Co. against the law firm Ansur...more

Pullman & Comley, LLC

Voluntary Disclosure of a Communication with Counsel: The CT Appellate Court Recognizes “Subject Matter” Waiver

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Accordingly, we hold that the voluntary disclosure of a privileged attorney-client communication constitutes a waiver of the privilege as to all other communications concerning the same subject matter when the trial court...more

Searcy Denney Scarola Barnhart & Shipley

What is the Status of Discovery of an Expert Witness Relationship?

In Wirley v. Central Florida Young Men’s Christian Association, 228 So.3rd 18 (Florida, 2017), the Supreme Court ruled disclosure of a financial relationship between a party, a plaintiff’s attorney and an expert, is no longer...more

Weber Gallagher Simpson Stapleton Fires &...

Court Rules That Attorney Client Privilege Waived With Ghost Written Disclaimer Letter

Two courts recently held that a disclaimer drafted by an insurer’s in-house or outside counsel and sent from the adjuster may constitute a waiver of the attorney client privilege. ...more

Kelley Drye & Warren LLP

Privilege and the Tripartite Insurer-Insured-Counsel Relationship

The tripartite insurer-insured-counsel relationship requires the insurer, its insured and the insured’s counsel to communicate with each other in the defense of a claim. In general, all parties work together to come to a...more

Burr & Forman

Making Adjustments: Insurers, Counsel, and the Attorney-Client Privilege

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Insurers often rely on counsel, external or otherwise, when addressing the validity and/or strength of claims filed by their insureds. However, there is a trend in the courts which makes the extent and nature of such reliance...more

White and Williams LLP

Coverage Counsel Authors Insurer’s Letters – Leads To Waiver of Attorney-Client Privilege

White and Williams LLP on

The other thing more unexciting than a discovery dispute is reading about someone else’s discovery dispute. But Wednesday’s decision from the Washington federal court in Canyon Estates Condominium Association v. Atain...more

Perkins Coie

South Carolina Attorney-Client Privilege Ruling Is a Gift to Insurers

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As Law360 recently reported, the South Carolina Supreme Court delivered a gift to insurers facing bad faith claims in that state. The court determined that, where a policyholder brings a bad faith claim against its insurer...more

Carlton Fields

Colorado Federal Court Rejects Attorney-Client Privilege for Communications Between Insurer’s Claims Adjuster and In-House Counsel

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In Olsen v. Owners Insurance Co., No. 1:18-cv-01665, 2019 WL 2502201 (D. Colo. June 17, 2019), the U.S. District Court for the District of Colorado found that neither the attorney-client privilege nor the work-product...more

White and Williams LLP

Sharing Privileged Communications: What Insurers and Reinsurers Need to Know

White and Williams LLP on

To balance the relative information inequality between an insurance company and its reinsurers, insurance companies often provide claim-related documents to their reinsurers. When some of those claim-related documents are...more

Cozen O'Connor

The Supreme Court of Texas Clarifies That a Party Can Testify as an Expert Witness without Waiving the Attorney-Client Privilege

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Litigation usually involves complex issues related to technology, products, or business processes. In many cases, clients are the best subject-matter experts of their craft....more

Butler Snow LLP

Bad Faith Insurance Defense and Reliance on Advice of Counsel

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In Mississippi, for a plaintiff to recover punitive damages against an insurance company for bad faith refusal to pay a claim or to fulfill an obligation existing under the terms of an insurance policy, the insured must be...more

Butler Weihmuller Katz Craig LLP

Attorney Client Privilege and Work Product Protection: Brief Overview

Claims investigations involving counsel often include communications relating to his or her understanding of the facts, opinions of relevant law, and recommendations. Oftentimes, claim notes or other claim file materials...more

Foley & Lardner LLP

Illinois Appellate Court Recognizes Common Interest Exception to Waiver of Privilege Rule

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On December 7, 2017, an Illinois appellate court held that co-defendants in a case who agree to share information pursuant to their common interest in defeating their litigation opponent do not waive either the...more

Maynard Nexsen

Waiver of Attorney-Client Privilege in Bad Faith Litigation

Maynard Nexsen on

The United States District Court has confirmed in a recent decision that in most circumstances, the attorney-client privilege will be waived in bad faith litigation in South Carolina. In Contravest, Inc. v. Mt. Hawley Ins....more

Butler Weihmuller Katz Craig LLP

Supreme Court says lawyer's referral of client to a doctor for treatment is attorney-client privileged communication, and out of...

The Florida Supreme Court declared that the attorney-client privilege shielded a motor vehicle accident plaintiff from being required to disclose that her attorney had referred her to a doctor for treatment. In Worley v....more

Carlton Fields

Extensive Use Of Attorney-Client Memo In Prior Lawsuit Destroyed Attorney-Client Privilege

Carlton Fields on

Insured companies sued Travelers for allegedly misrepresenting the scope of coverage afforded for asbestos injury claims under certain Excess Overlayer Indemnity policies. At issue has been the discoverability of a memorandum...more

Zelle  LLP

The Attack on Attorney-Client Privilege in Insurance Cases

Zelle LLP on

Policyholder lawyers are a creative group. One of the more recent manifestations of this creativity is the attempt to attack the attorney-client privilege in the context of insurance coverage disputes. While these attacks...more

Proskauer - Minding Your Business

New York’s Highest Court Refuses to Expand the Common Interest Doctrine to Merging Parties

On June 9, 2016, the New York Court of Appeals issued a stark reminder to transactional lawyers: no matter how much “common interest” two parties may have with respect to a transaction, the common interest doctrine may not...more

Cozen O'Connor

Will Discovery Unlock Your Claim File? Federal or State Court Jurisdiction Could Make The Difference

Cozen O'Connor on

Differences between federal court and state court procedure can be important for insurers that find themselves involved in “bad faith” litigation. If a lawsuit alleging extracontractual claims is filed in federal court, or...more

Carlton Fields

Court Lays Out Various Guidelines For Asserting Privilege In Insurance And Reinsurance Related Discovery

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The court considered the various privilege assertions of both the insurers (plaintiffs) and the insureds (defendants) in a multi-insurer insurance litigation. In analyzing varying categories of documents, including subsets of...more

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