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New York Court Holds Work of Insurer’s Expert Prior to Fire Origin and Cause Determination Was Not Work-Product Protected

In New York Schools Insurance Reciprocal v. Milburn Sales Co., Inc., 963 N.Y.S. 2d 152, 105 A.D.3d 716 (2nd Dep’t 2013), the New York Appellate Division, Second Department, narrowed the protection afforded by the work-product doctrine to investigations performed by

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