This section contains the nature of the case and procedural background.

Langdon (P) sought production of an insurance adjustor's files that were prepared prior to commencement of suit and the involvement of an attorney for Champion (D). The matter involved a personal injury action by P against D. D's insurance company and its adjuster became aware of the claims of P and D gave a recorded statement to his insurance adjuster. This was done before the involvement of an attorney for D. P requested production of those documents and D objected on grounds of work product and attorney-client privilege. The trial court refused, and P appealed.

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