Curtis et al v. Progressive Northern Insurance Company

Filing 114

MEMORANDUM OPINION AND ORDER, granting in part and denying in part 87 Plaintiff's Motion to Compel. Signed by Magistrate Judge Suzanne Mitchell on 5/1/19. (lb)

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF OKLAHOMA
RACHEL CURTIS, Individually
and on Behalf of All Others
Similarly Situated,
Plaintiff,
v.
PROGRESSIVE NORTHERN
INSURANCE COMPANY,
Defendant.

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Case No. CIV-17-1076-PRW

MEMORANDUM OPINION AND ORDER
This matter comes before the Court on Plaintiff’s motion to compel
Defendant to produce certain documents listed on its privilege log. Doc. 87.
Defendant filed a response, Doc. 98, and upon order of this Court submitted
the documents in question for in camera review. See Doc. 105. This and all
pending discovery matters were referred to the undersigned Magistrate Judge
for determination pursuant to 28 U.S.C. § 636(b)(1)(A). Docs. 104, 111. The
undersigned has conducted an in camera review of the documents in question
and grants Plaintiff’s motion in part as described below.

I.

Background.
Plaintiff’s claim rises out of Defendant’s use of software developed by

non-party Mitchell, Inc. Plaintiff claims this use of the Mitchell software
results in an undervaluation of the total loss amount due to Progressive policy
holders, including Plaintiff. See Doc. 33.
The parties have been engaged in discovery as to these claims since
January 30, 2018. On August 28, 2018, Defendant submitted its first privilege
log.

See Doc. 88.

The parties have subsequently corresponded and held

conferences without court intervention regarding Defendant’s claims of
privilege pursuant to Fed. R. Civ. P. 37. The parties reached some resolution
and Defendant has produced additional documents through that process but
maintains its claims of privilege over other disputed documents. Defendant
submitted a revised privilege log on January 29, 2019. See Doc. 93. The parties
held a Rule 37 conference on February 8, 2019 regarding the revised privilege
log but did not resolve any additional issues. Plaintiff requests production of
four separate email chains dated: (1) May 21-23, 2013, Doc. 98, Ex. 7, at 2, Nos.
8-11; (2) June 12-13, 2013, id. at 2-3, Nos. 12, 14-18; (3) July 30-31, 2015, id.
at 5, Nos. 49-50; and (4) January 27, 2017 and February 7, 2017, id. at 6-7, No.
69. The relevance of these documents to the claims at issue is undisputed.

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II.

Analysis.
Rule 26(b)(1) provides that parties may obtain discovery “regarding any

matter, not privileged, that is relevant to the claim or defense of any party. . . .”
Thus, to be discoverable under Rule 26, material must be both relevant to a
party’s claims or defenses and non-privileged.
Federal Rule of Evidence 501 provides that state law controls the
application of the attorney-client privilege in this case. Frontier Ref., Inc. v.
Gorman-Rupp Co., Inc., 136 F.3d 695, 699 (10th Cir. 1998). Under Oklahoma
law, the privilege protects confidential communications between an attorney
and a client “who consults [the] attorney with a view towards obtaining legal
services or is rendered professional legal services by an attorney.” Okla. Stat.
tit. 12, § 2502(A)(2), (B). To be protected, the communication must be made for
the purpose of obtaining legal advice. Id. § 2502(B). The party asserting the
privilege has the burden of establishing the privileged status of the
communication. Chandler v. Denton, 741 P.2d 855, 865 (Okla. 1987).
Section § 2502 also provides, in relevant part:
A client has a privilege to refuse to disclose and to
prevent any other person from disclosing confidential
communications made for the purpose of facilitating
the rendition of professional legal service to the client:

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1.
Between the client or a representative of the
client and the client’s attorney or a representative of
the attorney;
2.
Between the attorney and a representative of
the attorney;
3.
By the client or a representative of the client or
the client’s attorney or a representative of the attorney
to an attorney or a representative of an attorney
representing another party in a pending action and
concerning a matter of common interest therein;
4.
Between representatives of the client or between
the client and a representative of the client; or
5.
Among attorneys and their representatives
representing the same client.
Id. § 2502(B)(1)-(5).
A “representative of the client” is:
a.
One having authority to obtain professional
legal services, or to act on advice rendered pursuant
thereto, on behalf of the client, or
b.
Any other person who, for the purpose of
effectuating legal representation for the client, makes
or receives a confidential communication while acting
in the scope of employment for the client[.]
Id. § 2502(A)(4)(a)(b). And:
A communication is “confidential” if not intended to be
disclosed to third persons other than those to whom
disclosure is made in furtherance of rendition of
professional legal services to the client or those
reasonably necessary for the transmission of the
communication.
Id. § 2502(A)(5).

4

The party asserting attorney-client privilege or work-product protection
has the burden of showing clearly that either or both apply. 1 BarclaysAmerican Corp. v. Kane, 746 F.2d 653, 656 (10th Cir. 1984); Peat, Marwick,
Mitchell & Co. v. West, 748 F.2d 540, 542 (10th Cir. 1984); see, e.g., Leblanc v.
Tex. Brine Co., LLC, No. CIV-16-1026-D, 2017 WL 913801, at *4 (W.D. Okla.
Mar. 7, 2017), appeal dismissed sub nom. Tex. Brine Co., LLC & Occidental
Chem. Corp., 879 F.3d 1224 (10th Cir. 2018); Sanchez v. Matta, 229 F.R.D. 649,
654 (D.N.M. 2004). A general assertion of privilege is insufficient. Id. So, with
respect to each document, Defendant must show (1) a confidential
communication; (2) between privileged persons; (3) made to assist in securing
legal advice or assistance for the client.
A.

Communications
between
Defendant
Progressive’s
management and Defendant’s in-house counsel.

The May 21-23, 2013 and June 12-13, 2013 email chains reflect
communications

between

members

of

Defendant’s

management

and

Defendant’s in-house counsel. Defendant contends these emails relate to a
draft presentation regarding the total loss process that was sent to in-house
counsel and other members of management for review and comment. Doc. 98,

Defendant asserts work-product protection in parts of its privilege log,
see Doc. 98, Ex. 7, Nos. 12-18, but Defendant makes no effort to carry its workproduct protection burden in the argument section of its opposition to
Plaintiff’s motion to compel. See Doc. 98.
1

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at 22-23.

Defendant posits the only relevant inquiry is whether these

communications were “made for the purpose of facilitating the rendition of
professional legal services to the client.” Id. at 21 (emphasis deleted) (citing
Okla. Stat. tit. 12, § 2502(B)). Defendant states the answer is undisputedly
yes and therefore the communications are protected by attorney-client
privilege.

Id.

However, Plaintiff maintains “there is no indication that

Progressive management was directly seeking legal advice or whether the
discussion was regarding business decisions.” Doc. 103, at 6.
Plaintiff argues if the communication “was not generated for the primary
purpose of obtaining legal advice, but rather was generated in the course of
making a business decision . . . As such, it does not come within the gambit of
the attorney-client privilege.” Id. at 7 (quoting Samson Res. Co. v. Internorth,
Inc., 1986 U.S. Dist. LEXIS 30971, at *2 (N.D. Okla. 1986)).

Plaintiff states

these emails go to the core of Plaintiff’s claims here and if the entries contain
business advice or questions concerning the business of working with the total
loss system, then no protection applies.
The Court will consider each potentially privileged email chain in turn.
1.

May 21-23, 2013 email chain.

Defendant states these documents reflect “John Retton, a member of
Progressive management, circulating a draft presentation regarding the total
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loss process to Progressive in-house attorney Tim Kerwin and other members
of Progressive Management for review and comment.” Doc. 98, at 22; see id.
Ex 7, Nos. 8-9.

Defendant argues the communication was “made for the

purpose of facilitating the rendition of professional legal advice from Mr.
Kerwin,” and the “email chain and draft presentation are therefore properly
designated as privileged.” Id.
Upon in camera review of these documents, the undersigned finds that
although Defendant’s in-house counsel is copied on the emails, the email sent
by Mr. Retton and Ms. Hartel were not sent “for the purpose of facilitating the
rendition of professional legal advice” as Defendant argues.

Rather, Mr.

Retton appears to seek business advice on the draft presentation concerning
the total loss process he attaches. And in the second email, dated May 23,
2013, Ms. Hartel responds to Mr. Retton’s email, providing additional slides
for the presentation. Neither email evinces a request for legal advice and
overall the undersigned finds the communications and attachments appear to
be business—not legal—in nature, and therefore, are not protected by the
attorney-client privilege. See Leblanc, 2017 WL 913801, at *4 (W.D. Okla. Mar.
7, 2017) (citing U.S. Postal Serv. v. Phelps Dodge Ref. Corp., 852 F. Supp. 156,
160 (E.D.N.Y. 1994) (stating that the attorney-client privilege “attaches only
to legal, as opposed to business, services” and protects communications “made
to the attorney acting in her capacity as counsel. If the communication[s] are
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made to the attorney in her capacity as a business adviser, for example, [they]
ought not be privileged.”), and then citing In re Grand Jury Subpoena Duces
Tecum, 731 F.2d 1032, 1037-38 (2d Cir. 1984), and then citing United States v.
Kovel, 296 F.2d 918, 922 (2nd Cir. 1961) (explaining that, to qualify for the
privilege, the confidential communication between client and attorney must be
made for the purpose of obtaining legal, not business, advice)).
The undersigned acknowledges that it may be the case—though not
apparent from the emails—that the communications had both a business and
legal purpose.

However, as Defendant points out in its response,

“communications copying attorneys are privileged if they are ‘intended to be
confidential and a dominant purpose of the communication was to obtain legal
advice.’” Doc. 98, at 16 n.5 (quoting U.S. Postal Serv. v. Phelps Dodge Ref.
Corp., 852 F. Supp. 156, 163 (E.D.N.Y. 1994)) (emphasis added).

“If the

communication involves both business and legal issues, the Court must
determine the primary or predominant purpose of the communication . . . . If
primarily a business purpose, the privilege does not attach and the document
must be produced.” Lindley v. Life Inv’rs Ins. Co. of Am, 267 F.R.D. 382, 39192 (N.D. Okla. 2010). And, even “[w]here . . . the legal and business purposes
of the communication are inextricably intertwined, the entire communication
is privileged only if the legal purpose outweighs the business purpose.” Id. at

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392. Here, the undersigned finds the legal purpose of the communications—if
any—was not the primary purpose.
The undersigned therefore grants Plaintiff’s motion to compel as to the
May 21-23, 2013 emails and attachments. See Doc. 98, Ex. 7, Nos. 8-11.
2.

June 12-13, 2013 email chain.

This email chain includes, in total, ten emails between Defendant
Progressive’s management and at times its in-house attorneys Timothy
Kerwin and Huong Vu.

Defendant states this email chain reflects

“communications between Progressive management and its in-house attorneys
Tim Kerwin and Huong Vu that were made for the purpose of facilitating the
rendition of legal advice from Mr. Kerwin regarding a regulatory investigation
related to Progressive’s total loss process.” Doc. 98, at 23 (citing id. Ex. 7, Nos.
12, 14-18). 2

Plaintiff maintains “there is no indication that Progressive

management was directly seeking legal advice or whether the discussion was
regarding business decisions.”

Doc. 103, at 6.

Plaintiff argues if the

communication “was not generated for the primary purpose of obtaining legal
advice, but rather was generated in the course of making a business

Defendant has produced the attachment listed at entry number 13 on its
privilege log. See Doc. 98, at 23 n.7.
2

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decision . . . As such, it does not come within the gambit of the attorney-client
privilege.” Id. at 7.
On its privilege log, Defendant describes these email chains as reflecting
“[c]onfidential communications prepared in connection with regulatory
investigation at the request of Progressive in-house counsel between
Progressive management and Progressive in-house counsel providing
information to facilitate the rendition of legal advice regarding total loss
process.” See, e.g., Doc. 98, Ex. 7, No. 12.
Upon in camera review of these emails,3 the undersigned finds, however,
that for the most part the communications do not contain legal advice or
strategy, nor do they disclose client confidences. The first four emails in the
chain, each dated June 11, 2013, neither copy nor seem to contemplate or refer
to the inclusion or input from counsel. They do request input from various nonlegal Progressive employees. When in-house counsel is copied to the fifth and
sixth emails in the chain—dated June 12, 2013—the communications again do
not seek legal advice or strategy, nor do they disclose any confidential
information to aid in the rendering of legal advice. In fact, the decisions

For ease of reference, the undersigned will refer to the emails as they
appear in chronological order at entry number 18 on Defendant’s revised
privilege log (Tab J in the binder provided to the Court for in camera review),
as this email chain is inclusive of all the emails at issue.
3

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mentioned in the emails reflect those made by non-legal Progressive employees
and do not reference any legal advice or strategy provided. “[T]he mere fact
that an attorney was involved in a communication does not automatically
render the communication subject to the attorney-client privilege,” Motley v.
Marathon Oil Co., 71 F.3d 1547, 1550-51 (10th Cir. 1995); rather, the
“communication between a lawyer and client must relate to legal advice or
strategy sought by the client.” United States v. Johnston, 146 F.3d 785, 794
(10th Cir. 1998). In re Grand Jury Proceedings, 616 F.3d 1172, 1182-83 (10th
Cir. 2010). That the emails generally communicate potential responses to a
regulatory investigation is not sufficient to withhold the documents pursuant
to attorney-client privilege.
The Court finds Defendant’s assertion of privilege sound as to the
seventh and eighth emails in the chain. These two emails—dated June 13,
2013—do reflect “confidential communications by a client to an attorney made
in order to obtain legal assistance from the attorney in his capacity as a legal
advisor” and are therefore protected by the attorney-client privilege. In re
Grand Jury Subpoena Duces Tecum Issued on June 9, 1982, 697 F.2d 277, 278
(10th Cir. 1983) (quoting Fisher v. United States, 425 U.S. 391, 403 (1976)).
The undersigned understands these emails as demonstrating Progressive
management and in-house counsel Huong Vu communicating in their
capacities as client and attorney in order to seek and provide legal advice to
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the client. The Court therefore denies Plaintiff’s motion to compel as to these
two communications between John Retton and Huong Vu, dated June 13, 2013.
The ninth email in the chain—dated June 13, 2013—from John Retton
to Progressive management and in-house counsel is not protected by the
attorney-client privilege as the message it conveys neither constitutes legal
advice, nor tends directly or indirectly to reveal the substance of a client
confidence.

Similarly, the final email circulated by in-house counsel to

Progressive management and employees does not constitute a privileged
attorney-client communication. In-house counsel Timothy Kerwin circulates—
without added legal advice, strategy, or insight—a document prepared by a
non-party. “[W]hen an attorney conveys to his client facts acquired from other
persons or sources, those facts are not privileged.”

In re Grand Jury

Proceedings, 697 F.2d at 1182-83 (citing In re Sealed Case, 737 F.2d 94, 99
(D.C. Cir. 1984), and then citing McCormick § 89 (The “prevailing rule [of the
attorney-client privilege] does not bar divulgence by the attorney of
information communicated to him or his agents by third persons[, n]or does
information so obtained become privileged by being in turn related by the
attorney to the client in the form of advice.”). Because the document is sent
from and to, among others, in-house counsel is insufficient to attach the
privilege.

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Accordingly, the Court grants Plaintiff’s motion to compel as to the
emails dated June 12-13, 2013 except for the top email at entry numbers fifteen
and sixteen on Defendant’s revised privilege log—from John Retton and Huong
Vu. See Doc. 98, Ex. 7. Defendant is to revise its privilege log to clearly
indicate that such documents continue to be withheld due to circumstances
described above and to provide redacted documents when produced as part of
longer email chains.
B.

Communications
Mitchell, Inc.

between

Defendant

and

Non-party

The July 30-31, 2015 and January 27, 2017 and February 7, 2017 email
chains reflect communications between management and in-house counsel of
Defendant and employees and in-house counsel at Mitchell International,
Inc.—the non-party vendor of the software Defendant uses to value total loss
vehicles in Oklahoma.
In determining whether the attorney-client privilege extends to
communications between a client and non-party, the first issue for the Court
is whether the non-party, Mitchell, is a “representative” of Defendant such that
the disclosure of otherwise privileged information to Mitchell would not
destroy the attorney-client privilege. See Okla. Stat. tit. 12, § 2502(A)(4)(a)(b).
Defendant argues this is the case and that because Mitchell acts as “the
functional equivalent of an employee” of Defendant under Oklahoma law, the
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disclosure of otherwise privileged information to non-party Mitchell does not
result in the automatic destruction of the attorney-client privilege. Doc. 98, at
17.
Defendant argues the nature of its relationship with Mitchell supports
its assertion of privilege over their communications. 4 Defendant states it
licenses WCTL from Mitchell and because Defendant relies on Mitchell
employees for their expertise on the products and services Defendant licenses
from Mitchell, Mitchell is a representative of Defendant.

Doc. 98, at 18.

Defendant also states “it is uncontroverted that Progressive Northern relies on
Mitchell employees to provide information about WCTL.” Id. And that this
involves “from time to time . . . Progressive Northern’s in-house counsel, and
other Progressive Northern employees acting at the direction of Progressive
Northern’s in-house counsel, requesting and sharing confidential information
with Mitchell representatives in connection with Progressive Northern’s and
other Progressive affiliate companies’ responses to lawsuits and regulatory

4
Defendant also makes brief reference to a “common legal interest”

shared by non-party Mitchell and Defendant’s affiliate companies, but does not
explicitly raise the common interest doctrine as a separate basis for privilege.
Doc. 98, at 19. Addressing Defendant’s passing reference to the doctrine, the
Court notes Defendant makes no showing that the documents at issue on its
privilege log “were made in the course of a joint-defense effort,” or “were
designed to further that effort.” See Grand Jury Proceedings v. United States,
156 F.3d 1038, 1042-43 (10th Cir. 1998).

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investigations.”

Id. at 19.

Defendant also argues the confidentiality

agreement between the two companies—that “all communications between the
two

companies

reflecting

‘product

information,

specifications

and

documentation’ must be kept strictly confidential,” id. at 18 (quoting Doc. 100,
at 4), demonstrates that Mitchell is a representative of Defendant.
Plaintiff disagrees, arguing the disclosure of any privileged information
to Mitchell employees waives such privilege. Doc. 103, at 3-4. Plaintiff argues
Mitchell and Progressive are separate and distinct corporate entities. Mitchell
employees are not “agents” that are controlled by Progressive but rather are
employees of a corporation that does business with Progressive.
employees are not clients of Progressive’s in-house counsel.

Mitchell

A non-party

sending correspondence and attachments to Progressive employees and inhouse counsel regarding business decisions is not “legal services to the client”
as contemplated by the plain language of § 2502.
Defendant cites a number of cases that strike the Court as not on point.
Defendant argues the communications found to be privileged in these cases are
similar to the Mitchell communications—when the non-party recipient of
attorney-client communications is “acting as the functional equivalent of an
employee of the client.” Doc. 98, at 17 (citing Roda Drilling Co. v. Siegal, 2009
WL 10676177, at *2 (N.D. Okla. Aug. 11, 2009) (upholding assertion of
privilege over communications between defendant and non-party who “acted
15

as an employee or representative” of defendant in connection with the
provision of legal advice)).

In the cases Defendant cites, the non-party

representatives were found to be intimately involved in the client’s legal
matters, often meeting with the client’s in-house counsel alone and attending
meetings with outside parties as a stated representative for the client. See In
Re Bieter Co., 16 F.3d 929, 939-40 (8th Cir. 1994); see also Roda Drilling Co.,
2009 WL 10676177, at *2; see also A.H. ex rel. Hadjih v. Evenflo Co., Inc., 2012
WL 1957302, at *5 (D. Colo. May 31, 2012).
Defendant has failed to show its relationship with non-party Mitchell
rises to this level.

Based on review of Defendant’s arguments and the

documents provided in camera, it does not appear that Mitchell employees
were “actively involved in furthering [Defendant’s in-house counsel
[representation of [Defendant].” See Sundance Energy Okla., LLC v. Dan D.
Drilling Corp., 2015 WL 348705, at *4 (W.D. Okla. Jan. 26, 2015). Defendant
even characterizes its relationship with Mitchell as involving the “requesting
and sharing” of confidential information “from time to time.” Doc. 98, at 19.
And, the communications from Mitchell employees to Progressive management
and in-house counsel—on July 30, 2015, January 27, 2017, and February 7,
2017, see id., Ex. 7, Nos. 49-50, 69—consists largely of restatements of its own
business practices. While the Mitchell employees are providing information at
the request of Defendant’s management and in-house counsel in relation to a
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“regulatory investigation” and regarding “state laws concerning total loss
process,” see id., in camera review reveals the nature of their responses do not
support Defendant’s claim that Mitchell employees acted as the “functional
equivalents” of employees of the client, Defendant. Rather, the information
they provide is typical of that provided between two companies who conduct
business with one another.
And, as Defendant admits, Defendant fails to cite any case law and it
appears none exists, wherein a court, interpreting Oklahoma’s privilege
statute’s “representative of the client” language, has extended the attorneyclient privilege to relationships similar to that between Defendant and nonparty Mitchell. As such, the undersigned refuses to do so now and because
non-party Mitchell is not a “representative” for purposes of § 2502, the
communications between Mitchell and Defendant cannot be withheld based on
attorney-client privilege.
The undersigned also notes that upon review of the privilege log
summaries and the emails themselves, it is not clear the questioned e-mails
could be characterized as a communication made for the purpose of facilitating
the rendition of legal advice. The flow of communication between Defendant’s
in-house counsel and Mitchell employees, while not dispositive, distinguishes
this claim of privilege from those the courts have upheld. In the cases cited by
Defendant and others reviewed by the Court, the potential waiver of privilege
17

most often involves the client’s attorney divulging information to an outside
agent of the client in order to further the attorney’s representation of the client.
Indeed, in reviewing the parties’ back-and-forth communications regarding
these claims of privilege, the undersigned notes Defendant points to several
cases in which several federal courts have pointed to this disclosure to third
persons. 5

Here, in both email chains at issue, the allegedly privileged

information is provided by the third party to Defendant’s in-house counsel. As
a result, the undersigned notes the nature and substance of these
communications, even if non-party

Mitchell could be considered a

“representative” of Defendant, does not implicate the purpose of the attorneyclient privilege, which is “to encourage ‘clients to make full and frank
disclosure to their attorneys, who are then better able to provide candid advice
and effective representation.’” Lindley, 267 F.R.D. at 388 (quoting Mohawk
Indus., Inc. v. Carpenter, 558 U.S. 100, 130 (2009) and Upjohn Co. v. United
States, 449 U.S. 383, 389 (1981)).

See Doc. 90, at 6 (citing inter alia SFF-TIR, LLC v. Stephenson, 2015 WL
3504882, at *2 (N.D. Okla. June 3, 2015) (protecting communications that were
“disclosed to third persons in furtherance of the rendition of professional legal
services to the client.”), and then citing Westinghouse Elec. Corp. v. Republic of
Phil., 951 F.2d 1414, 1424 (3d Cir. 1991) (“When disclosure to a third party is
necessary for the client to obtain informed legal advice, courts have recognized
exceptions to the rule that disclosure waives the attorney-client privilege.”)).
5

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The undersigned therefore grants Plaintiff’s motion to compel as to the
July 30-31, 2015, January 27, 2017 and February 7, 2017 communications
between Defendant and non-party Mitchell. See Doc. 98, Ex. 7, Nos. 49-50, 69.6
III.

Conclusion.
As more fully described above, the Court grants Plaintiff’s motion to

compel as to the following documents:
1.

May 21-23, 2013 emails and attachments. See Doc. 98, Ex.
7, Nos. 8-11;

2.

June 12-13, 2013 emails. See id. Nos. 12, 14, 17, 18; and

3.

July 30-31, 2015, January 27, 2017 and February 7, 2017
communications between Defendant and non-party Mitchell.
See id. Nos. 49-50, 69.

The Court denies Plaintiff’s motion to compel the emails dated June 13,
2013 located at entries fifteen and sixteen of Defendant’s revised privilege log.
Defendant is to revise its privilege log to clearly indicate that such documents

The Court acknowledges but will not address certain accusations raised
in Defendant’s response. See Doc. 98, at 26-28. Defendant’s nearly three pages
of summary—even if accurate—do not aid the Court in its present decision.
That Plaintiff may or may not have improperly withheld discovery is not now
before the Court. The Court advises both parties that it does not entertain
such recapitulation of the parties’ back-and-forth disagreements as to
discovery matters unless the issues are being raised for the Court’s review,
and contain arguments supported by case law and other sources for the Court’s
consideration.
6

19

continue to be withheld due to circumstances described above and to provide
redacted documents when produced as part of longer email chains.
IT IS SO ORDERED this 1st day of May, 2019.

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