Work-Product Privilege Does Not Shield Carrier's Emails to Insurance Agency

The Montana Workers’ Compensation Court ruled that an insurance carrier is required to turn over emails its attorney sent to an agency that a worker had used to secure a policy. Case: Raines v. Technology Insurance Co., No. 2020-4996, 08/05/2020, published. Facts: Edward Raines is the owner of VGR Lawn Maintenance LLC. He obtained a workers' compensation insurance policy from the Technology Insurance Co. through Payne West Insurance, an independent agent. Raines' contact at Payne West was Diana Deyo. Raines elected to be included as a covered employee. In May 2018, h...