Olson v. First National Insurance Company of America

CourtDistrict Court, W.D. Washington
DecidedFebruary 3, 2020
Docket2:19-cv-00322
StatusUnknown

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

Bluebook
Olson v. First National Insurance Company of America, (W.D. Wash. 2020).

Opinion

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE

8 KATHLEEN OLSON, CASE NO. C19-322 RSM

9 Plaintiff, ORDER

10 v.

11 FIRST NATIONAL INSURANCE COMPANY OF AMERICA, et al., 12 Defendants. 13 14 I. INTRODUCTION 15 This matter is before the Court on the parties’ LCR 37 Submission Regarding Request 16 for Production No. 2. Dkt. #19. The parties seek expedited consideration of their discovery 17 dispute. The Court resolves the issue as follows. 18 II. BACKGROUND 19 Plaintiff is pursuing an action against Defendant, her insurer, for damages sustained in a 20 car accident. Dkt. #1-2 at ¶ 11. Plaintiff previously brought an action against the at-fault driver 21 and ultimately settled for the driver’s policy limits on September 24, 2018. Id. at ¶ 15. On the 22 basis that she had not been fully compensated for her loss, Plaintiff sought uninsured motorist 23 (“UIM”) benefits from Defendant. Id. at ¶ 17. Plaintiff made her first demand to Defendant on 24 October 4, 2018. Id. at ¶ 18; Dkt. #22-1. Defendant refused to offer any additional benefits and 1 Plaintiff initiated this action seeking contractual and extracontractual claims related to 2 Defendant’s handling of her claims. Dkt. #1-2. 3 Plaintiff served discovery requests on May 22, 2019. Request for Production No. 2 of 4 those requests sought Defendant’s “complete file relative to the subject matter.” Dkt. #19 at 3. 5 In response, Defendant provided much of its claim file, “but redacted those portions identifying

6 reserves set and evaluations of Plaintiff’s claims.” Id. at 2. Citing the work product doctrine, 7 Defendant asserts that it “redacted only portions of its claim file created after Plaintiff’s demand,” 8 at which time it reasonably anticipated litigation. Id. at 3. Plaintiff seeks unredacted copies of 9 five specific pages, the opportunity to depose Defendant’s adjuster, any undisclosed records, and 10 attorneys’ fees. Id. at 2. The parties met and conferred but were unable to resolve the dispute. 11 III. DISCUSSION 12 A. Legal Standard 13 The Federal Rules of Civil Procedure1 provide the Court broad discretion to control 14 discovery. Branch v. Umphenour, 936 F.3d 994, 1005 (9th Cir. 2019) (district court’s “decision

15 to deny discovery will not be disturbed except upon the clearest showing that denial of discovery 16 results in actual and substantial prejudice to the complaining litigant”) (quoting Hallett v. 17 Morgan, 296 F.3d 732, 751 (9th Cir. 2002)). The scope of permissible discovery is also broad: 18 Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, 19 considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ 20 resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. 21

22 1 Under the Erie Doctrine, a federal court sitting in diversity applies federal procedural law and the substantive law of the forum state. Erie R.R. Co. v. Tompkins, 304 U.S. 64, 78 (1938). 23 Applicable here, the work product doctrine is a procedural immunity governed by the Federal Rules of Civil Procedure. See Union Pacific R. Co. v. Mower, 219 F.3d 1069, 1077 n.8 (9th Cir. 24 2000); Lexington Ins. Co. v. Swanson, 240 F.R.D. 662, 666 (W.D. Wash. 2007). 1 Information within this scope of discovery need not be admissible in evidence to be discoverable. 2

3 FED. R. CIV. P. 26(b)(1). Where requested discovery is not answered, the requesting party may 4 seek to compel such discovery. FED. R. CIV. P. 37(a)(1). “The party who resists discovery has 5 the burden to show that discovery should not be allowed, and has the burden of clarifying, 6 explaining, and supporting its objections.” Cable & Computer Tech., Inc. v. Lockheed Sanders, 7 Inc., 175 F.R.D. 646, 650 (C.D. Cal. 1997). 8 B. Defendant Does Not Establish That the Relevant Redactions Are Protected 9 Defendant asserts work product protection as the only basis for the redactions at issue. 10 Work product protection prevents “exploitation of a party’s efforts in preparing for litigation.” 11 Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 576 (9th Cir. 1992) (quoting Admiral 12 Ins. Co. v. United States District Court, 881 F.2d 1486, 1494 (9th Cir. 1989)). The doctrine is 13 incorporated into the Federal Rules of Civil Procedure, providing that parties ordinarily “may not 14 discover documents and tangible things that are prepared in anticipation of litigation or for trial 15 by or for another party or its representative (including the other party’s attorney, consultant, 16 surety, indemnitor, insurer, or agent).” FED. R. CIV. P. 26(b)(3)(A). 17 To be considered work product, documents “must: (1) be ‘prepared in anticipation of 18 litigation or for trial’ and (2) be prepared ‘by or for another party or by or for that other party’s 19 representative.’” United States v. Richey, 632 F.3d 559, 567 (9th Cir. 2011) (quoting In re Grand 20 Jury Subpoena, Mark Torf/Torf Envtl. Mgmt. (Torf), 357 F.3d 900, 907 (9th Cir. 2004)). 21 Documents serving dual litigation and business purposes, must further be created “because of” 22 litigation. Id. at 567–68. That is, “taking into account the facts surrounding their creation, their 23 litigation purpose so permeates any non-litigation purpose that the two purposes cannot be 24 discretely separated from the factual nexus as a whole.” Torf, 357 F.3d at 910. 1 Defendant does not satisfy its burden here. First, Defendant does not clearly establish the 2 date upon which it reasonably anticipated litigation. Defendant relies on unsupported assertions 3 that litigation was anticipated as of the date Defendant received Plaintiff’s UIM demand letter. 4 Defendant presumably relies on the testimony of its claims adjuster, Lyoan Mey. But the adjuster 5 only testifies to receiving the demand letter for the policy limits, “stating that the ‘total value’ of

6 Plaintiff’s claim ‘far exceeds the $200,000 in available insurance.’” Dkt. #22 at ¶ 2. Only 7 defense counsel concludes that the “difference in assessed value provided [Defendant] with a 8 reasonable expectation that the parties would be forced to litigate their dispute.” Dkt. #19 at 3. 9 Secondly, Defendant does not adequately establish that the redacted material was created 10 “because of” the prospect of litigation. Rather, the adjuster again testifies that she “completed 11 [Defendant’s] analysis of Plaintiff’s claim.” Dkt. #22 at ¶ 3. The adjuster appears to have treated 12 Plaintiff’s claim as it would any other—seeking a medical evaluation and considering the 13 materials provided. The record does not establish that the material at issue was created because 14 of the prospect of litigation.

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Olson v. First National Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/olson-v-first-national-insurance-company-of-america-wawd-2020.