Trzesniowski v. Erie Insurance Exchange

59 Pa. D. & C.2d 44, 1973 Pa. Dist. & Cnty. Dec. LEXIS 494
CourtPennsylvania Court of Common Pleas, Mercer County
DecidedJanuary 11, 1973
Docketno. 112
StatusPublished
Cited by3 cases

This text of 59 Pa. D. & C.2d 44 (Trzesniowski v. Erie Insurance Exchange) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Mercer County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trzesniowski v. Erie Insurance Exchange, 59 Pa. D. & C.2d 44, 1973 Pa. Dist. & Cnty. Dec. LEXIS 494 (Pa. Super. Ct. 1973).

Opinion

ACKER, J.,

The matter for determination arises from motion for protective order to a request for inspection of tangible things pursuant to Pennsylvania Rule of Civil Procedure 4009(1). Roughly denominated that which is desired for inspection is the entire file of defendant insurance company gathered in preparation for a suit in trespass in which the present plaintiff recovered a verdict against defendant’s insured on February 24, 1971, in the total amount of $79,002, of which defendant insurance company has paid $26,999. Defendant’s insured, Roger Wayne Beggs, then assigned on March 29, 1972, all of his claim against the Erie Insurance Exchange under the policy of insurance covering the above-mentioned accident. Wherefore, the present plaintiff comes before this court as an assignee standing in the shoes of the insured and with all of the rights of the insured under the policy. It is claimed in plaintiff’s complaint that on January 18, 1971, prior to the trial, counsel for the plaintiff injured party orally offered to settle the case for $25,000, being within the coverage. Further, on January 28, 1971, counsel for plaintiff by a letter of that date to counsel for defendant insurance carrier renewed the offer of $25,000 to settle the matter plus the property damage. Further, by that letter it is asserted by the author that in his opinion [46]*46defendant would be acting in bad faith by not settling and thereby could escape from the . . very good possibility of a recovery over and above the insurance limits.”

Of the 10 paragraphs containing requests for inspection of tangible personal property, all are subject to a motion for protective order: Five because they allegedly relate to matters under the attorney-client relationship and all 10 because they are protected by the anticipation of litigation rule.

There does not appear to be a recorded Pennsylvania case directly in point.

The procedure followed by plaintiff in this case of taking an assignment of a right of the insured against his carrier was specifically approved in Gray v. Nationwide Mutual Insurance Company, 422 Pa. 500, 223 A. 2d 8 (1966). There, as well as the leading case of Cowden v. Aetna Casualty and Surety Company, 389 Pa. 459, 134 A. 2d 223 (1957), the requirement of the insurance company to act in a fiduciary capacity obligating it in utmost faith to perform its responsibilities without allowing its interest to dominate over those of the insured is delineated. The concept of good faith was also used by the Superior Court in Szarmack v. Welch, 220 Pa. Superior Ct. 407, 289 A. 2d 149 (1972), where the insurance companies are required to disclose the amount of coverage to fulfill their obligation of good faith.

CONFIDENTIAL COMMUNICATIONS CONTENTION

The legislature of Pennsylvania by the Act of May 23, 1887, P. L. 158, sec. 5, cl. (d), 28 PS §321, provides: “Nor shall counsel be competent or permitted to testify to confidential communications made to him by his [47]*47client or the client be compelled to disclose the same, unless in either case this privilege be waived upon the trial by the client.” First it is to be noted that by the very language of the statute the limitation is not upon what counsel may have told the client but only that which the client told to the counsel. However, if the communication by the client to the attorney is to be disclosed in unveiling a return communication by the attorney, so much as was received by the attorney from the client continues to be privileged: Eisenman v. Hornberger, 44 D. & C. 2d 128 (1967). However, another well recognized rule must be considered under the facts of this case. That is if the attorney represents both parties to the transaction in disputes between the parties inter se the confidential communications statute is inapplicable: Loutzenhiser v. Doddo, 436 Pa. 512, 260 A. 2d 745 (1970). As stated in Tracy v. Tracy, 377 Pa. 420, 105 A. 2d 122 (1954), at 424: “Nor, by overwhelming authority, does the rule apply if the attorney represented both parties to the transaction, in which case no communications in relation to the common business are privileged in favor or against either, but only against a common adversary.” This principle was relied upon to deny the use of the confidential communications statute in a case similar upon its facts of LaRocca v. State Farm Mutual Automobile Insurance Company, 47 F.R.D. 278 (1969).

Wherefore, we conclude the confidential communication rule is of no help to defendants.

WORK PRODUCT OR ANTICIPATION OF LITIGATION

Pennsylvania Rule of Civil Procedure 4011(d) prevents the disclosure of matters secured in anticipation of litigation. The succinct question, of course, is what litigation.

[48]*48It is the contention of defendant that the litigation referred to must include the possibility of an action founded upon bad faith after the principle litigation and, therefore, all is protected. Plaintiff contends that the only litigation referred to is that giving rise to the present litigation; and, in that the principle suit has long since terminated and in fact was required to be terminated before the present suit could be commenced, there is no further protection under the procedural rules: Grew v. Brunner, 1 D. & C. 2d 754 (1955). Although the work product and material obtained in anticipation of litigation may not be completely identical, they are sufficiently synonymous to be dealt with together in this opinion for it is basically the attorney’s work product and advice of counsel which is the subject of this request for inspection. The rational of the attorney work product rule is set forth in Hickman v. Taylor, 329 U.S. 495, 67 S. Ct. 385 (1947), at page 393:

“An attorney’s thoughts, heretofore inviolate, would not be his own. Inefficiency, unfairness and sharp practices would inevitably develop in the giving of legal advice and on the preparation of cases for trial. The effect on the legal profession would be demoralizing. And the interests of the clients and the cause of justice would be poorly served.”

The work product rule has been held not to terminate with the case: LaRocca v. State Farm Mutual Automobile Insurance Company, at page 282, supra. However that rule is but a qualified privilege and loses the status at least under the Federal Rules of Civil Procedure when good cause is shown for its abandonment: Fed. R. Civ. P. 34. Using the test of good cause, if there be such, the work product rule must fall: LaRocca v. State Farm Mutual Automobile Insurance Company, supra. Further, the work product privilege [49]*49does not prevent disclosure of documents which relate to settlement negotiations found in the file of the attorney: Bourget v. Government Employees Insurance Company, infra. Because of the assignment in this case plaintiff stand in the same position as the insured and letters written to the liability insurance carrier by the attorney retained by it can be the subject of production in an action by an assignee of the policy holder’s rights to recover excess payment: Shapiro v. Allstate Insurance Company, 44 F.R.D. 429 (1968).

FAILURE TO SPECIFICALLY DESIGNATE THE TANGIBLE THINGS DESIRED

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Bluebook (online)
59 Pa. D. & C.2d 44, 1973 Pa. Dist. & Cnty. Dec. LEXIS 494, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trzesniowski-v-erie-insurance-exchange-pactcomplmercer-1973.