Edy v. Farmers Property Casualty Ins. Co.

Citations

• 2024 Ohio 1047

Syllabus

DISCOVERY – ATTORNEY-CLIENT PRIVILEGE – CIV.R. 26: The trial court did not err when it ordered production of defendant insurer's claims file up to the date of a benefits payment where plaintiffs insureds alleged that defendant unreasonably delayed the processing, handling, and payment of their benefits claim in bad faith. The trial court did not err when it ordered the production of defendant insurer's claims file without conducting an in-camera inspection for privileged attorney-client communications where defendant's conclusory statements failed to establish the existence of privileged documents.