Discovery of Communications with Claims Administrator • Discovery of Mock Deposition • Attorney-Client Privilege • Work Product Doctrine
Brown v. Greyhound Lines Inc., PICS Case No. 16-0702 (Pa. Super. May 24, 2016) Shogan, J. (40 pages).
Communications between a party’s contracted claims administrator and counsel retained by the claims administrator for the party were not protected by attorney-client privilege or the work product doctrine where the documents merely included the result of the claims administrator’s investigation and failed to include any mental impressions, opinions or conclusions regarding any potential claim or defense in litigation. Trial court order affirmed.