Claims File Materials Are Not Discoverable For Contract Claims Against Auto Insurer

(August 21, 2019, 12:32 PM EDT) -- CINCINNATI — An auto insurer is not required to produce materials protected by the work product doctrine or attorney-client privilege in its claims file or to produce its representatives for depositions regarding the materials until after the breach of contract and declaratory judgment claims are resolved because the materials relate to the bad faith claim, which was bifurcated from the contractual claims, the First District Ohio Court of Appeals said Aug. 16 (Stephen Loukinas, et al. v. State Farm Mutual Automobile Insurance Co., No. C-180462, Ohio App., 1st Dist., 2019 Ohio App. LEXIS 3387)....

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