Evanston Insurance Company v. Murphy

CourtDistrict Court, D. Arizona
DecidedJuly 31, 2020
Docket2:19-cv-04954
StatusUnknown

This text of Evanston Insurance Company v. Murphy (Evanston Insurance Company v. Murphy) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Evanston Insurance Company v. Murphy, (D. Ariz. 2020).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Evanston Insurance Company, No. CV-19-04954-PHX-MTL

10 Plaintiff, ORDER

11 v.

12 Tracey Portee Murphy, et al.,

13 Defendants. 14 15 This matter arises from the issuance of a subpoena duces tecum under Federal Rule 16 of Civil Procedure 45. Plaintiff/Counterdefendant Evanston Insurance Company 17 (“Evanston”) asks the Court to compel production of documents subpoenaed from 18 investigator Keith Tolhurst and Tolhurst International, LLC (“Tolhurst”). (Doc. 69.) 19 Defendants/Counterclaimants Tracee Portee Murphy, et al. (“Murphy”) ask the Court to 20 deny Plaintiff’s motion and to provide work-product protection for the documents. 21 (Doc. 68.) Plaintiff has replied. (Doc. 70.) The Court has considered the parties’ briefs and 22 supporting submissions, as well as the joint summary of the discovery dispute (Doc. 55). 23 For the following reasons, the Court will grant Plaintiff’s motion. 24 I. BACKGROUND 25 Raymond Canty (“Canty”) d/b/a Soul Brothers Motorcycle Club (“Soul Brothers”) 26 purchased a commercial general liability policy, with a $2 million policy limit, from 27 Evanston in anticipation of Soul Brothers’ annual fish fry event held on April 6-7, 2017. 28 At the event, Arthur Murphy, Jr. was shot and killed. The family of the deceased filed a 1 wrongful death lawsuit against Canty and other named defendants in the Superior Court of 2 Arizona for Maricopa County (the “Underlying Action”). See Murphy v. Pearce Lincoln 3 Props., LLC, No. CV2019-001932 (Ariz. Super. Ct. July 1, 2020). Evanston contends the 4 purchased policy excludes claims stemming from assault or battery. It denied coverage and 5 declined to tender a defense for Canty, Soul Brothers, or any other insureds in the 6 Underlying Action. 7 In 2019, Murphy’s counsel hired Tolhurst to locate Canty in order to negotiate a 8 Damron agreement between the adverse parties in the Underlying Action.* The executed 9 agreement assigned a $9 million judgment against Soul Brothers and the other insureds in 10 the Underlying Action. Evanston contends the Damron agreement was fraudulent and/or 11 collusive and that it is Murphy’s burden to show otherwise. Evanston thus argues that the 12 circumstances surrounding Canty’s negotiation and execution of the Damron agreement is 13 a central issue and that they are entitled to discover such information. Evanston deposed 14 Canty and asked him about his communications with Tolhurst and Murphy’s counsel. 15 Canty had trouble recalling ever meeting with Tolhurst or Murphy’s counsel; he likewise 16 was not able to testify to any specifics from any meetings or the circumstances surrounding 17 the Damron agreement. Evanston has now subpoenaed Tolhurst’s investigative file as it 18 relates to the Canty investigation and Damron agreement negotiations. 19 II. WORK-PRODUCT DOCTRINE 20 Federal common law governs the issue of work-product privilege presented here. 21 See Fed. R. Evid. 501; United States v. Zolin, 491 U.S. 554, 562 (1989). To qualify as 22 privileged work product, the material must be (1) a document or tangible thing, (2) 23 prepared by or for counsel or its representative, (3) in anticipation of litigation or for trial. 24 See Fed. R. Civ. P. 26(b)(3)(A); United States v. Nobles, 422 U.S. 225, 237-38 (1975);

25 * Damron agreements stem from an Arizona Supreme Court decision. See generally Damron v. Sledge, 105 Ariz. 151 (1969). The Ninth Circuit has confirmed their usage as a 26 “settlement agreement between an insured and an injured party in circumstances where the insurer has declined to defend a suit against the insured.” Quihuis v. State Farm Mut. Auto. 27 Ins. Co., 748 F.3d 911, 912 n.1 (9th Cir. 2014). The insured accepts liability for the underlying incident and assigns its rights against the insurer to the injured party. The 28 injured party relieves the insured of liability and agrees to recover from only the insurance company. Id. 1 Hickman v. Taylor, 329 U.S. 495, 508 (1947); United States v. Richey, 632 F.3d 559, 567- 2 68 (9th Cir. 2011). The doctrine extends to documents or materials compiled by an 3 investigator working at an attorney’s direction in preparation for litigation. Nobles, 4 422 U.S. at 238–39; see also Fed. R. Civ. P. 26(b)(4)(D) (providing similar protection from 5 discovery of “facts known or opinions held” by a non-testifying expert retained in 6 anticipation of litigation). The privilege is qualified and waivable. Nobles, 422 U.S. at 239. 7 When material is created by an attorney or his investigator for the singular purpose 8 of preparation for litigation, it is clearly privileged work product. However, when the 9 material may be said to have a “dual purpose, that is, where it was not prepared exclusively 10 for litigation,” the determination of privilege is more difficult. Richey, 632 F.3d at 568. The 11 Ninth Circuit employs the “because of” test to determine if material created with a dual 12 purpose is work product. See id. Dual-purpose documents are considered work product if, 13 based on the totality of the circumstances of the case and the particular document’s nature, 14 it “can be fairly said to have been prepared or obtained because of the prospect of 15 litigation . . . and would not have been created in substantially similar form but for the 16 prospect of that litigation.” Id. (quoting In re Grand Jury Subpoena (Mark Torf/Torf Envtl. 17 Mgmt.), 357 F.3d 900, 907-08 (9th Cir. 2004)); see also Charles Alan Wright, Arthur R. 18 Miller, and Richard L. Marcus, 8 Federal Practice & Procedure § 2024 (2d ed. 1994). 19 III. DISCUSSION 20 Evanston subpoenaed four categories of documents: Tolhurst’s fee agreement with 21 Murphy’s counsel, Tolhurst’s billing invoices, and correspondence and notes detailing 22 Tolhurst’s investigation of Canty’s whereabouts and their subsequent meeting with Canty 23 regarding the Damron agreement and Canty’s declaration. (Doc. 69, p. 3; Doc. 55, p. 2.) 24 Murphy argues that the Tolhurst information is shielded from discovery as work product, 25 relying on the idea that Tolhurst’s communications and documents were prepared in 26 anticipation of the current litigation. (Doc. 68, p. 2.) Evanston argues that the documents 27 do not qualify as work product, because they were not prepared in anticipation of litigation. 28 (Doc. 69, p. 3-4.) In the alternative, Evanston argues that the privilege was otherwise 1 waived and that they have met the burden of showing applicable exceptions to any privilege 2 protection. (Id.) 3 Because application of the privilege “can derogate from the search for the truth,” it 4 is narrowly construed and the party invoking the doctrine “bears the burden of establishing 5 all the elements that trigger the protection; doubts must be resolved against the party 6 asserting the privilege.” United States v. 22.80 Acres of Land, 107 F.R.D. 20, 22 (N.D. Cal. 7 1985). If the party seeking protection meets their initial burden, the party seeking discovery 8 then carries the burden that an exception or waiver applies.

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Related

Hickman v. Taylor
329 U.S. 495 (Supreme Court, 1947)
United States v. Nobles
422 U.S. 225 (Supreme Court, 1975)
United States v. Zolin
491 U.S. 554 (Supreme Court, 1989)
United States v. Richey
632 F.3d 559 (Ninth Circuit, 2011)
Damron v. Sledge
460 P.2d 997 (Arizona Supreme Court, 1969)
RLI Insurance v. Conseco, Inc.
477 F. Supp. 2d 741 (E.D. Virginia, 2007)
Yolanda Quihuis v. State Farm Mutual Automobile I
748 F.3d 911 (Ninth Circuit, 2014)
Bradfield v. Mid-Continent Casualty Co.
15 F. Supp. 3d 1253 (M.D. Florida, 2014)
Rogers v. Giurbino
288 F.R.D. 469 (S.D. California, 2012)
United States v. 22.80 Acres of Land
107 F.R.D. 20 (N.D. California, 1985)

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Evanston Insurance Company v. Murphy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/evanston-insurance-company-v-murphy-azd-2020.