[WSBAPT] Declaration of Completion/Request for accounting

[Brent Williams-Ruth]

Hi Diane -

I will say that I have never done it in this context, but in my prior life
as an Insurance Defense Coverage Attorney where the invoices between us and
the insurer came in - we would redact EVERY element of attorney-client
communication.  Example - Receive, analyze, and respond to Insurer Name
correspondence seeking clarification on the standard for determining the
difference between substantial structural impairment and imminent danger of
collapse.  (that is the unredacted) and what we would keep uncovered from
the redacting tape would be as follows: Receive, analyze, and respond to
Insurer Name correspondence

I have a case with a PGAL who is seeing my invoices and I use that same
standard - I show that I had a call or communication with the Executor, but
remove any reference to what was discussed.

This standard (in the insurance litigation world) has been upheld by both
federal and state judges alike. If there is pressure for more - you can
always do a review "in camera" with just the judge to establish that it
truly is A/C protected or not.

Brent

*Brent Williams-Ruth* (pronouns: he/him)
*Attorney-At-Law*

*Law Offices of Brent Williams-Ruth, **a division of BWR Consulting, PLLC*

*Physical Address: 500 S 336th Street, Suite 214; Federal Way, WA 98003*

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e-mail <Brent at Williams-RuthLaw.com> / website
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On Tue, Aug 31, 2021 at 11:17 AM Diane J. Kiepe <DJKiepe at depdslaw.com>
wrote:

> Hello All,
>
>
>
> When a beneficiary (directly or through counsel) files a TEDRA in response
> to Declaration of Completion requesting, or asserting their rights to an
> accounting of PR Fees and Attorney Fees, can you tell me what information
> you provide in your experience?  I am mostly concerned about
> attorney/client privilege.  I clearly want to be cooperative and provide
> the accounting but I also need to be mindful of my obligations to my client.
>
>
>
> Any insights or thoughts would be greatly appreciated.
>
>
>
> *Diane J. Kiepe*
>
>
>
> Diane J. Kiepe
>
> Douglas Eden
>
> 717 W. Sprague Ave.
>
> Suite 1500
>
> Spokane, WA  99201
>
> djkiepe at depdslaw.com
>
> 509-455-5300
>
>
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