In Baxter Int'l, Inc. v. AXA Versicherung, 320 F.R.D. 158 (N.D. Ill. 2017), the issue was discoverability in the insured's action for indemnification. The defendant insurer failed to show in that case that correspondence with its co-insurers and reinsurers was protected by the work product doctrine. More specifically, the carrier's correspondence at issue was concerned with how much coverage was available to the insured with respect to the underlying claims.
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