(1) Failure to discover the accrual of a self-concealing claim in a complex transaction tolls the statute of limitations. (2) Communication between insured and insurer falls under attorney-client privilege if legal advice was given respecting a concrete claim. (3) Documents rendered after a claim file was opened and while investigating the claim, even if litigation is not in process, may fall under work product privilege.
Draggin’ Y Cattle Co., Inc. v. Addink, 2013 MT 319,
0 Mont. L. Rev.
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