Trull v. Mag Mutual Insurance Company

District Court, S.D. West Virginia·Decided September 24, 2025·No. 3:24-cv-00202·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

HUNTINGTON DIVISION

DEVAN TRULL, D.O.,

Plaintiff,

v. CIVIL ACTION NO. 3:24-0202

MAG MUTUAL INSURANCE COMPANY,

Defendant.

MEMORANDUM OPINION AND ORDER Pending before the Court is Defendant MAG Mutual Insurance Company’s Objection to Magistrate Judge Tinsley’s September 5, 2025 Order, ECF No. 221. ECF No. 226. The Order granted in part and denied in part Defendant’s Motion for Protective Order, ECF No. 172. For the reasons described below, the Court DENIES the objection. I. Background1 Defendant MAG Mutual Insurance Company (MagMutual) asks the Court to grant its Motion for Protective Order to strike or limit the scope of topics in the Rule 30(b)(6) Deposition of a representative of MagMutual. Def.’s Obj. to Magistrate Judge Tinsley’s Sept. 5, 2025 Order (“Def.’s Obj.”), ECF No. 226, at 1, 4. This discovery dispute arises out of Plaintiff Dr. Trull’s pending claims against Defendant that originated from a medical professional liability lawsuit against Dr. Trull (the underlying litigation).

1 Background information is borrowed from Trull v. W. Virginia Mut. Ins. Co., Civ. A. No. 3:24- 0202, 2025 WL 1690148 (S.D. W. Va. June 16, 2025). The underlying litigation began in early 2020, when Dr. Trull faced a lawsuit brought by a former patient. At the time, Dr. Trull was covered by an insurance policy issued by West Virginia Mutual Insurance Company (WVMIC) which merged into MAG Mutual Insurance Company (MagMutual) during the underlying litigation.2 The jury returned a verdict of $1,922,395.67

against Dr. Trull in the underlying litigation. A settlement between the patient and a different physician led this Court to reduce the jury’s verdict by $500,000. On May 17, 2024, the Court entered the Amended Judgment, concluding the underlying litigation. Pursuant to the WVMIC Policy, WVMIC issued a $1,000,000 check to the claimant, leaving over $400,000 of the judgment outstanding. On April 18, 2024, Dr. Trull brought the present suit claiming that Defendants must pay the remaining portion of the judgment based on a failure to settle within policy limits despite having opportunities to do so. Dr. Trull originally brought several claims against Defendant, some of which were dismissed. See ECF No. 123. The Shamblin claim remains, and the Court took no position on whether Dr. Trull pled a statutory bad faith claim. Id. On June 13, 2025, Dr. Trull filed a Notice of Rule 30(b)(6) Deposition of a representative of

MagMutual. ECF No. 130. Defendant filed a Motion for Protective Order to limit the deposition topics. ECF No. 172. After full briefing, Magistrate Judge Tinsley entered an Order granting the protective order in part and denying in part3 to which Defendant now objects. The Court has reviewed the briefs on this issue and now considers the objection below. I. Legal Standard Federal Rule of Civil Procedure 72(a) allows a party to object to a magistrate judge’s ruling on

2 MagMutual assumed all liability of WVMIC, and WVMIC was dismissed as of September 4, 2025. Stipulation and Dismissal of WVMIC as a Def., ECF No. 216. 3 Order Directing Def.’s Mot. for Protective Order is Granted in Part and Denied in Part (“Sept. 5, 2025 Order”), ECF No 221. non-dispositive matters, including discovery. A district court may modify or set aside any portion of an order if it is “clearly erroneous or is contrary to law.” Fed. R. Civ. P. 72(a). Under the “clearly erroneous” standard, “findings of fact will be affirmed unless [the court’s] review of the entire record leaves [the court] with the definite and firm conviction that a mistake

has been committed.” Harman v. Levin, 772 F.2d 1150, 1153 (4th Cir. 1985); Spurlock v. Wexford Health Sources, Inc., Civ. A. No. 3:23-0476, 2025 WL 451688, at *1 (S.D. W. Va. Feb. 10, 2025). However, “[w]hen . . . review of a non-dispositive motion by a district judge turns on a pure question of law, that review is plenary under the ‘contrary to law’ branch of the Rule 72(a) standard.” Robinson v. Quicken Loans Inc.., Civ. A. No. 3:12-0981, 2013 WL 1704839, at *3 (S.D. W. Va. Apr. 19, 2013) (citing PowerShare, Inc. v. Syntel, Inc., 597 F.3d 10, 15 (1st Cir. 2010)). “This means that, for questions of law, there is no practical difference between review under Rule 72(a)’s ‘contrary to law’ standard and [a] de novo standard.” Id. II. Analysis

Rule 26(b)(1) of the Federal Rules of Civil Procedure states in part, “[p]arties 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 . . . [i]nformation within this scope of discovery need not be admissible in evidence to be discoverable.” Additionally, the Court must limit discovery otherwise allowed if it is “unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive.” Fed. R. Civ. P. 26(b)(2)(C). The dispute concerns topics 3, 4, 5, 6, 7, and 12 of Plaintiff’s Rule 30(b)(6) Deposition of

MagMutual. Def.’s Obj. 4. Defendant claims the topics are irrelevant, burdensome and/or not proportional to the needs of the case and asks the Court to strike or narrow topics by geographic and temporal scope. Id. at 1, 4; Def.’s Reply in Supp. of Obj., ECF No. 231, at 2, 6, 9. The topics in dispute as they stand based on Magistrate Judge Tinsley’s September 5, 2025 Order follow: Topic No. 3: No All facts, witnesses, and documents regarding any reviews, audits, or examinations conducted by Mag Mutual Insurance Company concerning its compliance with West Virginia state laws applicable to the handling of insurance claims, including, but not limited to, West Virginia Insurance Regulations, West Virginia state statutes related to claims handling, such as the Uniform Trade Practices Act, and/or any other applicable West Virginia state law, policy, and procedure since November 1, 2020.

Def.’s Mot. for Protective Order, ECF No. 172, at 4. Magistrate Judge Tinsley limited the above to “information related to MagMutual’s internal review and audit of West Virginia claims involving excess verdicts from November 1, 2020, through the present.” Sept. 5, 2025 Order, ECF No. 221, at 5, 7. Topic No. 4: All facts, witnesses, and documents regarding any and all extra contractual bad faith suits against Mag Mutual Insurance Company for a period of the last ten (10) years.

Sept. 5, 2025 Order 7. Def.’s Mot. for Protective Order 4.

Topic No. 5: All facts, witnesses, and documents regarding any and all findings by any judicial, administrative, or executive tribunal that Mag Mutual Insurance Company and/or its agents violated any insurance policy improperly denying benefits for a period of the last ten (10) years.

Def.’s Mot. for Protective Order 4. As limited to “findings related to bad faith resulting from excess verdicts.” Sept. 5, 2025 Order 9. Topic No. 6: All facts, witnesses, and documents regarding any finding by a judicial tribunal within the last ten (10) years that Mag Mutual Insurance Company (1) violated the Uniform Trade Practices Act in West Virginia; or (2) was found to have acted in bad faith related to excess verdicts.

Sept. 5, 2025 Order 11. Topic No.

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