Shaterian v. MAPFRE Insurance Company

CourtDistrict Court, W.D. Washington
DecidedJune 5, 2025
Docket2:24-cv-01509
StatusUnknown

This text of Shaterian v. MAPFRE Insurance Company (Shaterian v. MAPFRE Insurance Company) 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
Shaterian v. MAPFRE Insurance Company, (W.D. Wash. 2025).

Opinion

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5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 11 MEELOD SHATERIAN, CASE NO. 2:24-cv-01509-TL 12 Plaintiff, ORDER ON MOTION TO COMPEL v. 13 MAPFRE INSURANCE COMPANY et al., 14 Defendants. 15

16 17 This matter is before the Court on Plaintiff’s Motion to Compel. Dkt. No. 19. Having 18 reviewed the motion, Defendants’ response (Dkt. No. 23), Plaintiff’s reply (Dkt. No. 25), and the 19 relevant record, the Court GRANTS IN PART and DENIES IN PART Plaintiff’s motion. 20 I. BACKGROUND 21 This is a bad-faith insurance complaint. See generally Dkt. No. 9 (amended complaint). 22 Plaintiff, Meelod Shaterian, alleges that, after his car was stolen, his insurer(s), Defendants 23 MAPFRE Insurance Company (“MAPFRE”) and Commerce West Insurance Company 24 (“Commerce West”) failed to honor the terms of his automobile insurance policy. See generally 1 id. Plaintiff’s amended complaint ascribes the alleged misconduct to “Meelod’s insurer,” but 2 Plaintiff’s pleading does not identify which Defendant is the actual insurer. See generally id. In 3 removing the original complaint to federal court, Defendants advised that “[t]he proper insuring 4 entity is Commerce West Insurance Company.” Dkt. No. 1 (notice of removal) at 1 n.1. Further,

5 the response to Plaintiff’s motion is titled “Commerce West’s Response to Plaintiff’s Motion to 6 Compel.” Dkt. No. 23 at 1. In light of this, the Court will construe “Meelod’s insurer” as 7 referring to Defendant Commerce West. 8 On March 7, 2024, Plaintiff’s 2019 Audi A4 was “stolen from in front of his residence in 9 Seattle, Washington.” Dkt. No. 9 ¶¶ 12–13. Plaintiff reported the theft to the Seattle Police 10 Department (“SPD”) and filed a claim with Defendant Commerce West. Id. ¶¶ 14–15. On March 11 8, 2024, Defendant Commerce West issued a reservation of rights letter to Amir Shaterian, 12 Plaintiff’s father.1 Id. ¶ 17. The letter noted that Defendant Commerce West had found “potential 13 inconsistencies with the presented claim.” Id. Some time after the alleged theft, SPD recovered 14 the A4, which “appeared to have been in an accident.” Id. ¶ 19. The vehicle was transported to

15 the home of Plaintiff’s parents where, “soon thereafter,” Defendant Commerce West inspected it. 16 Id. ¶¶ 20–21. 17 On June 6, 2024, Plaintiff filed an administrative complaint with the Washington State 18 Office of Insurance Commissioner (“OIC”), asserting his dissatisfaction with his insurer’s 19 handling of the claim. Dkt. No. 20-1 (Ex. A) at 4–5 (OIC complaint). In his administrative 20 complaint, Plaintiff wrote, “I have no idea what to do next, or how to get my claim resolved. I 21 fear legal action is my only option with my insurer refusing to act in good faith or adhere to my 22 comprehensive coverage.” Id. at 5. On June 7, 2024, OIC transmitted the complaint to Defendant 23 1 Plaintiff alleges that Defendant Commerce West “issued an insurance policy to [Plaintiff] and his family, insuring 24 [] five of their vehicles.” Dkt. No. 9 ¶ 9. 1 MAPFRE and directed the insurer to respond by July 1, 2024. Id. at 2–3 (OIC letter).2 On June 2 26, 2024, having determined that “the loss did not occur as reported,” Defendant Commerce 3 West notified Plaintiff that it had denied his claim. Id. ¶¶ 22–23. 4 On August 20, 2024, Plaintiff filed a civil action against Defendant MAPFRE in King

5 County Superior Court. See Dkt. No. 1-2 (complaint). On September 20, 2024, Defendant 6 MAPFRE removed the complaint to district court. Dkt. No. 1 (Notice of Removal). On October 7 17, 2024, Plaintiff filed an amended complaint that added Commerce West as a defendant. Dkt. 8 No. 9. Defendants answered (Dkt. No. 10), and the Court set a trial date of October 20, 2025 9 (Dkt. No. 12). The Court established May 23, 2025, as the deadline to complete discovery. Id. 10 On April 23, 2025, Plaintiff filed the instant motion to compel. Dkt. No. 19. 11 II. LEGAL STANDARD 12 Federal Rule of Civil Procedure 26 allows parties to obtain discovery regarding: 13 any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the 14 importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the 15 parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed 16 discovery outweighs its likely benefit.

17 Fed. R. Civ. P. 26(b)(1). For purposes of discovery, “Relevant information . . . is information 18 reasonably calculated to lead to the discovery of admissible evidence.” Pizzuto v. Tewalt, 136 19 F.4th 855, 868 (9th Cir. 2025) (cleaned up). “[B]road discretion is vested in the trial court to 20 permit or deny discovery.” Hallett v. Morgan, 296 F.3d 732, 751 (9th Cir. 2002). 21 Under Federal Rule of Civil Procedure 37, “a party seeking discovery may move for an 22 order compelling an answer, designation, production, or inspection.” Fed. R. Civ. P. 37(a)(3)(B). 23 2 The Court omits at this time a lengthy recitation of the alleged shortcomings in Defendant Commerce West’s 24 handling of Plaintiff’s claim. See Dkt. No. 9 ¶¶ 23–31. 1 The court may order a party to provide further responses to an “evasive or incomplete disclosure, 2 answer, or response.” Fed. R. Civ. P. 37(a)(4). The party seeking to compel discovery has the 3 burden of establishing that its requests are relevant. Fed. R. Civ. P. 26(b)(1). However, once this 4 showing is made, the party seeking a protective order must “carry a heavy burden of showing

5 why discovery” should be denied. Blankenship v. Hearst Corp., 519 F.2d 418, 429 (9th Cir. 6 1975). 7 III. DISCUSSION 8 Plaintiff asks the Court to compel Defendant Commerce West to produce the entire claim 9 file for the claim at issue in this case. See Dkt. No. 19 at 6. Although Defendant Commerce West 10 has produced portions of the claim file in response to a request for production, they have refused 11 to produce “any materials created after June 7, 2024—the date Plaintiff allegedly ‘threatened 12 litigation’ by filing an Office of the Insurance Commissioner complaint.” Id. at 1. Defendant 13 Commerce West asserts that such materials are “protected by the work-product doctrine [and] 14 attorney-client privilege,” and that they were “prepared in anticipation of litigation.” Dkt.

15 No. 20-2 (Ex. B) at 3–4; see Dkt. No. 23 at 5. 16 A. Attorney–Client Privilege 17 In bad-faith insurance claims in Washington, there is a presumption of discoverability for 18 the insurer’s claim file for the claim that underlies the allegations of bad faith. See Cedell v. 19 Farmers Ins. Co. of Wash., 176 Wn.2d 686, 696–97, 699, 295 P.3d 239 (2013). As the 20 Washington Supreme Court observed in Cedell, “[t]he insured needs access to the insurer’s file 21 maintained for the insured in order to discover facts to support a claim of bad faith.

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