There is no time limit to the anticipation of litigation, a Lackawanna County judge has ruled, deciding that plaintiffs cannot discover the mental impressions of an insurance company’s representative predating the filing of a lawsuit.

The issue of first impression came in Church of the Forgotten Souls v. NGM Insurance Co. , in which the plaintiff, doing business as Heaven Help Us Thrift Store, attempted to serve its insurer with a “complete claim file” after an insurance adjustor evaluated its property damage claim.

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