Security National Insurance Company v. Construction Associates of Spokane Inc

District Court, E.D. Washington·Decided May 6, 2021·No. 2:20-cv-00167·Unknown

Opinion

EASTERN DISTRICT OF WASHINGTON May 06, 2021 SEAN F. MCAVOY, CLERK SECURITY NATIONAL INSURANCE No. 2:20-CV-0167-SMJ COMPANY, ORDER GRANTING, IN PART, Plaintiff, DEFENDANTS’ MOTION TO v. COMPEL, DENYING PLAINTIFF’S MOTION FOR PROTECTIVE CONSTRUCTION ASSOCIATES OF SPOKANE, INC.; and MARK AND MATERIALS FOR IN CAMERA REVIEW Defendants. BEFORE THE COURT is a motion to compel discovery by Defendants Mark and Jennifer Wilson. ECF No. 72. The motion was referred to the undersigned magistrate judge on April 14, 2021, ECF No. 76, the motion was argued in open court on May 4, 2021, and the matter was taken under advisement. A. Factual Background In 2016, Plaintiff Security National Insurance Company issued a liability policy to Merit Electric of Spokane, Inc. (“Merit Electric” or “Merit”). On August 30, 2016, Defendant Mark Wilson, an employee of Merit Electric, was working on a project at the Paulsen Center located at 421 W. Riverside, Ave., Spokane, Washington. On that date, Defendant Mark Wilson sustained a work-related injury at the Paulsen Center. Defendants Mark and Jennifer Wilson thereafter sued Defendant Construction Associates of Spokane, Inc. (“Construction Associates” or “CAS”) as a result of the Paulsen Center injury. On September 3, 2019, CAS contacted the insurance broker of Merit Electric at Alliant Insurance Services, Inc. (“Alliant”) requesting a Certificate of Insurance (“COI”) that might serve as evidence of additional insured (“AI”) coverage for CAS under Merit Electric’s liability insurance. On September 3, 2019, Alliant emailed a copy of a Certificate of Insurance issued March 29, 2016 to CAS on behalf of Merit Electric for work performed by Merit Electric on the Coeur d’Alene Courthouse Plaza project. A later email submitted by Alliant contained a Certificate of Insurance, dated September 3, 2019, that purportedly applied retroactively to the 2016 liability policy, conferring additional insured status to CAS with respect to general liability for Merit Electric’s operations as the electrical subcontractor on the Paulsen Center remodel project. CAS, viewing the September 3, 2019 Certificate of Insurance generated by Alliant as applicable and binding, sought to have Plaintiff Security National defend and indemnify CAS against the lawsuit filed by Defendants Mark and Jennifer Wilson. Plaintiff Security National advised CAS that the information was insufficient to demonstrate CAS was an additional insured under Merit Electric’s policy. Therefore, Plaintiff Security National denied defense and indemnity to CAS as an additional insured on the insurance policy issued to Merit Electric. Defendant CAS subsequently entered into a settlement agreement with Defendants Mark and Jennifer Wilson and assigned its rights against Plaintiff Security National to Defendants Mark and Jennifer Wilson. B. Procedural Background On April 30, 2020, Plaintiff Security National brought this action against Defendants for declaratory judgment, misrepresentation, insurance fraud and violation of Wash. Rev. Code § 48.01.030. Defendants have filed counterclaims for breach of contract, violation of Washington State’s Insurance Fair Conduct Act, violations of Washington State’s Consumer Protection Act, violations of the duty of good faith, negligence, coverage by estoppel, and damages pursuant to the Olympic Steamship doctrine. A 10-day jury trial is scheduled for December 6, 2021. ECF No. 63. On April 5, 2021, Defendants filed the instant motion to compel discovery. ECF No. 72. Plaintiff filed a combined response and motion for a protective order on April 19, 2021, ECF No. 78, and an amended response on April 26, 2021, ECF No. 84. Defendants filed a reply on April 26, 2021, ECF No. 82, and an additional reply on May 3, 2021, ECF No. 87. The foregoing discovery dispute has been referred to the undersigned for resolution. ECF No. 76. C. Legal Standard The purpose of discovery is to make trial “less a game of blind man’s bluff and more a fair contest with the basic issues and facts disclosed to the fullest practicable extent possible,” United States v. Procter & Gamble, 356 U.S. 677, 683 (1958), and to narrow and clarify the issues in dispute, Hickman v. Taylor, 329 U.S. 495, 501 (1947). Fed. R. Civ. P. 26(b)(1) establishes the scope of discovery and states in pertinent part:

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, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable. “The party who resists discovery has the burden to show that discovery should not be allowed, and has the burden of clarifying, explaining, and supporting its objections.” Oakes v. Halvorsen Marine Ltd., 179 F.R.D 281, 283 (C.D. Cal. 1998); Nestle Foods Corp. v. Aetna Casualty & Surety Co., 135 F.R.D. 101, 104 (D. N.J. 1990). D. Motion to Compel Discovery Based on the briefing of the parties and the argument presented at the hearing, the Court believes there are four categories of discovery being challenged as improperly withheld from disclosure: (1) communications regarding the handling, processing, investigating and evaluating of the claim in this case (Cedell materials); (2) information asserted by Plaintiff as proprietary; (3) claims handling manuals or materials; and (4) underwriting documents.

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Security National Insurance Company v. Construction Associates of Spokane Inc, (E.D. Wash. 2021).

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Related

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