Daily Archives: Monday, November 13, 2017

Posted: November 13, 2017

Reports Prepared by Consultant During Investigation of Claims Held Not Privileged or Work Product

On November 9, 2017, the Third Department issued a decision in NYAHSA Services, Inc., Self-Insurance Trust v. People Care Inc., 2017 NY Slip Op. 07909, holding that a report evaluating litigation claims prepared by a consultant engaged by counsel was not privileged or entitled to protection as work product, explaining: During this collection litigation, Cool... Read more »