News & Analysis as of

Insurance Litigation Work-Product Doctrine

Cozen O'Connor

Southern District Court of New York Permits Extensive Discovery of Reserve And Reinsurance Information in Bad Faith Litigation

Cozen O'Connor on

In Mandarin Oriental, Inc. v. HDI Glob. Ins. Co. et al., Civil Action No. 23 Civ. 4951, 2025 WL 1638071 (S.D.N.Y. June 10, 2025), the District Court of the Southern District of New York followed the modern trend and allowed...more

Carlton Fields

Florida Appellate Court Affirms Work Product Protection for Insurer’s Claim File

Carlton Fields on

In Family Security Insurance Co. v. Stein, No. 4D22-1468 (Fla. 4th DCA Feb. 8, 2023), Florida’s Fourth District Court of Appeal confirmed that, in a coverage action where the issue of coverage is in dispute, an insurer’s...more

Chartwell Law

Florida Court Rules Documents Contained Within an Underwriting or Claims File are Protected Work Product

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For years, the plaintiff’s bar has taken the position that there is no “claims file privilege.” This mantra is repeated without any explanation regarding why this phrase is somehow sufficient to compel production of documents...more

Cozen O'Connor

Claim Investigation Not Necessarily Protected by Work Product Doctrine in Illinois

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In determining when the work product doctrine is triggered, the Northern District of Illinois recently held that, rather than adopting a bright-line rule, the issue should be decided on a case-by-case basis at the court’s...more

McGuireWoods LLP

Several Courts Deal With First-Party Insurance Work Product Issues

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In first-party insurance scenarios, an insured seeks coverage directly from its insurance company for its losses (in contrast to third-party insurance, in which an insured seeks its insurance company’s help defending and...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

Rivkin Radler LLP

New York Insurance Coverage Law Update

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United States District Court Orders Insured To Produce Certain Pre-Litigation Documents But Not Others Deemed Work Product 99 Wall sued Allied World seeking coverage under a property policy for water losses at 99 Wall’s...more

Blank Rome LLP

New York Courts Skeptical of Insurers Seeking to Hide Coverage Analysis as Privileged

Blank Rome LLP on

One of the most basic discovery requests in insurance coverage litigation is for the insurer’s claims-handling documents and coverage analysis. A policyholder suing for insurance coverage is entitled to understand the...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

Carlton Fields

South Carolina Federal Court Denies Motion to Stay and Orders Insurer to Produce Documents

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The background of this case is as follows. In 2014, ContraVest Inc., ContraVest Construction Co., and Plantation Point Horizontal Property Regime Owners Association Inc. (collectively, “Plaintiffs”) brought suit in South...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

Robinson+Cole Property Insurance Coverage...

Work Product and Attorney-Client Privilege Concerning Documents Drafted Prior To Litigation: Eastern District Of New York Finds...

Insurers retain outside counsel during claim investigations for a variety of reasons, including, among others, providing coverage advice, assisting in reviewing and responding to communications with insureds that have legal...more

Carlton Fields

The Privilege Maintains Its Power: Texas Supreme Court Blocks Discovery of Insurer Attorney’s Billing Information

Carlton Fields on

When (if ever) are an insurer’s attorney’s fees and billing information discoverable in a coverage dispute? Though the question is straightforward, the answer can vary from case to case and jurisdiction to jurisdiction. The...more

Clark Hill PLC

SCOTX Ends the “My Fees Are Smaller Than Your Fees” Squabble

Clark Hill PLC on

How many times have you said, upon receiving your opponent’s demand for attorneys’ fees, “That’s outrageous! Our fees are a fraction of that amount!”? Until recently, Texas law was unsettled as to whether you could defend the...more

Carlton Fields

Discovery Opinions Show Limits Of Privilege And Broad Standard Of Relevance

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Three recent opinions issued by courts highlight the scope and limitations of a party’s right to discovery of reinsurance, reserve and allegedly privileged information in insurance coverage disputes....more

Cozen O'Connor

Insurers Beware: Defending Bad Faith Claim May Lead to Waiver of Privileged Communications

Cozen O'Connor on

On July 27, 2016, the United States District Court for South Carolina ordered an insurer to turn over its privileged communications. The Court explained that the insurer waived the protections afforded under the...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

Insurer Not Required To Produce Coverage Memoranda Or Reinsurance Information In Discovery

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A federal district court in New York has held that the attorney-client and work-product privileges apply to coverage memoranda sought by an insured from AIG Specialty Insurance in an ongoing coverage and bad faith litigation...more

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