[WSBAPT] Declaration of Completion/Request for accounting

[Diane J. Kiepe]

Thanks for the input.  It is much appreciated.

Diane J. Kiepe

Diane J. Kiepe
Douglas Eden
717 W. Sprague Ave.
Suite 1500
Spokane, WA  99201
djkiepe at depdslaw.com<mailto:djkiepe at depdslaw.com>
509-455-5300

From: wsbapt-bounces at lists.wsbarppt.com <wsbapt-bounces at lists.wsbarppt.com> On Behalf Of Brent Williams-Ruth
Sent: Tuesday, August 31, 2021 4:25 PM
To: WSBA Probate & Trust Listserv <wsbapt at lists.wsbarppt.com>
Subject: Re: [WSBAPT] Declaration of Completion/Request for accounting

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

**EFFECTIVE IMMEDIATELY** All mail sent through the USPS should be sent to the following address: PO BOX 3319; Federal Way, WA 98063

Office/Scheduling Phone: (253) 285-7751

Direct: (253) 285-7453

e-mail<mailto:Brent at Williams-RuthLaw.com> / website<http://www.williams-ruthlaw.com/> / facebook<http://www.facebook.com/bwrlaw> /


On Tue, Aug 31, 2021 at 11:17 AM Diane J. Kiepe <DJKiepe at depdslaw.com<mailto: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<mailto:djkiepe at depdslaw.com>
509-455-5300

***Disclaimer: Please note that RPPT listserv participation is not restricted to practicing attorneys and may include non-practicing attorneys, law students, professionals working in related fields, and others.***
_______________________________________________
WSBAPT mailing list
WSBAPT at lists.wsbarppt.com<mailto:WSBAPT at lists.wsbarppt.com>
http://mailman.fsr.com/mailman/listinfo/wsbapt
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mailman.fsr.com/pipermail/wsbapt/attachments/20210901/5c7c7ae8/attachment.html>