Trull v. West Virginia Mutual Insurance Company

District Court, S.D. West Virginia·Decided August 13, 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,

Plaintiff,

v. CIVIL ACTION NO. 3:24-cv-00202

WEST VIRGINIA MUTUAL INSURANCE COMPANY, et al.,

Defendants.

ORDER

This matter is before the undersigned on the Motion to Quash Subpoena for Rule 30(b) Deposition filed by subpoenaed non-party, Cabell Huntington Hospital (“CHH”), on April 25, 2025. (ECF No. 113). Therein, CHH seeks an order quashing the subpoena served by Defendant West Virginia Mutual Insurance Company (“WVMIC”) which directs CHH to produce a corporate designee for deposition under Rule 30(b) of the Federal Rules of Civil Procedure. Also pending are WVMIC’s Motion to Compel CHH’s Production of Documents Pursuant to Subpoena (ECF No. 117) and Defendants’ Motion for Leave to Supplement Status Report, filed July 17, 2025. (ECF No. 166). For the reasons set forth herein, Defendants’ Motion for Leave to Supplement Status Report (ECF No. 166) is GRANTED, CHH’s Motion to Quash Subpoena (ECF No. 113) is DENIED, and WVMIC’s Motion to Compel (ECF No. 117) is GRANTED. I. BACKGROUND Plaintiff, Devan Trull, D.O., is a medical professional who was sued by a former patient, Ms. Hensley, for medical negligence in April 2020. (ECF No. 47). At the time of care, Plaintiff had medical professional liability coverage through Defendant Mag Mutual (“MM”). (Id. at 2). MM was acquired by Defendant West Virginia Mutual Insurance

Company (“WVMIC”) in November 2020, at which “took over the handling of the underlying medical professional liability claim” at that time. (Id.). According to Plaintiff, WVMIC is “merely the alter ego” of Defendant MM. (Id. at 8). During litigation of that claim, Ms. Hensley made a demand to settle within the applicable policy limits. (Id. at 3). The terms of the proposed settlement would include a complete release of liability for Plaintiff. (Id.). Plaintiff’s counsel forwarded the settlement offer to counsel for Defendant MM. (Id. at 4). The offer email, dated September 13, 2023, contained an explicit warning to Defendant MM from Ms. Hensley’s counsel that failure to settle within policy limits would constitute prime facie evidence of Defendant MM’s failure to act in Plaintiff’s best interest and would be deemed to constitute bad faith. (Id. at 3-4). Plaintiff’s personal counsel sent a separate letter dated October 9, 2023, advising

Defendant MM that Plaintiff “[did] not want to risk her personal assets in the event of a verdict . . . for compensatory damages, which, if obtained in this case, likely would be far in excess of her policy limits.” (Id. at 5 (quoting ECF No. 47-2)). Accordingly, Plaintiff’s counsel demanded Defendant MM settle the case within Plaintiff’s policy limits. (Id.). Despite these warnings and repeated demands from Plaintiff to settle the case, Defendant MM refused to settle and proceeded to try the case before a jury. (Id. at 4). On March 8, 2024, a jury returned a verdict of $1,922,395.67 in favor of Ms. Hensley against Plaintiff—an amount that far exceeded Plaintiff’s policy limit of $1,000,000. (Id. at 6). As a result, Plaintiff is personally liable for the excess judgment. Based on the Defendants’ failure to settle within policy limits despite ample opportunity to do so, Plaintiff filed suit against Defendants on April 18, 2024, alleging, inter alia, a claim under Shamblin v. Nationwide Mut. Ins. Co., 183 W.Va. 585, 396 S.E.2d 766 (1990).

On January 13, 2025, CHH responded to a request from Defendants for information related to Plaintiff’s Self Insurance coverage offered through Plaintiff’s employment with CHH. (ECF No. 76-1). In that missive, counsel for CHH explained that there was no coverage under Plaintiff’s plan “because CHH was never given notice or an opportunity to participate in the defense, settlement negotiations, and the like.” (Id. at 2). According to CHH, this lack of notice “unquestionably prejudiced CHH,” and the result of that prejudice is “no coverage for Dr. Trull with respect to the allegations asserted against her by [Ms. Hensley] as well as the resulting adverse verdict.” (Id.). On March 14, 2025, Defendants moved to add CHH as a necessary party to this litigation so the Court could determine whether certain self-insurance coverage maintained by CHH provides excess coverage for the verdict rendered against Plaintiff in

the underlying medical malpractice action. (ECF No. 90). While that motion was pending, WVMIC served upon CHH a subpoena seeking to compel certain testimony from a corporate designee under Rule 30(b) of the Federal Rules of Civil Procedure on fourteen designated areas of inquiry. See (ECF Nos. 105, 113, 114). On April 25, 2025, CHH moved to quash that subpoena, arguing that it would place an undue burden on CHH, especially if CHH were to be added as an additional party to the suit after the deposition took place. (ECF No. 113 ¶¶ 5-6). On May 6, 2025, WVMIC moved to compel CHH’s production of documents under the subpoena. (ECF No. 117). On June 16, 2025, the Court denied Defendants’ motion to add CHH as a party on June 16, 2025, concluding that Defendants had “failed to show that CHH is a necessary party to this proceeding” because “CHH played no role in Defendants’ alleged bad faith and is wholly unnecessary to such relief.” (ECF No. 140 at 12-13). On June 17, 2025, the Court directed the parties and CHH to each file a Status Report to the extent they wished

to address the effect of the Court’s Order denying joinder on the pending Motion to Quash, as well as WVMIC’s pending Motion to Compel CHH’s production of documents. (ECF No. 141). The parties and CHH filed their respective Status Reports on June 24, 2025. (ECF No. 144, 147, 148). Defendants filed a Consolidated Response to Plaintiff and CHH’s Status Reports on July 1, 2025 (ECF No. 152), and Plaintiff filed a Response on July 2, 2025 (ECF No. 154). On July 17, 2025, Defendants moved for leave to supplement their Status Report with additional discovery responses from Plaintiff. (ECF No. 166). The Court directed the remaining parties to file any responses in opposition to that motion no later than July 25, 2025. (ECF No. 168). Plaintiff filed her Response on July 25, 2025. (ECF No. 177). The matters are ready for adjudication.

II. LEGAL STANDARD Rule 26(b)(1) of the Federal Rules of Civil Procedure generally provides for broad discovery in civil actions. Specifically, the Rule provides that, “[u]nless otherwise limited by court order . . . [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, 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.” Fed. R. Civ. P. 26b)(1). Pursuant to this broad scope of discovery, the Rule further provides that information “need not be admissible in evidence to be discoverable.” Id. Thus, it is well-established that “relevancy for discovery purposes is defined more broadly than relevancy for evidentiary purposes,” and extends to any information which may “bear on” a party’s claim or defense. Becton,

Dickinson & Co. v.

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