The Attorney as Insurance Adjuster
On December 5, 2003, the California Court of Appeal, in 2,022 Ranch, LLC v. The Superior Court of San Diego County, concluded that an attorney working for an insurance company (as either an employee or outside counsel), who conducts tasks sometimes conducted by insurance adjusters, has no work product protection for those tasks. In addition, its client may not be able to assert the attorney-client privilege.
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