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In SER Montpelier v. Bloom, et al., No. 13-1172, (W.Va., April 10, 2014), the Supreme Court of Appeals of West Virginia addressed third-party disclosure exception to the attorney-client privilege. As discussed more fully below and in the linked Opinion, the Court found that: (1) coverage opinion letters are protected by attorney-client privilege, (2) seminar and training materials generated by outside counsel for benefit of carrier are protected, but (3) billing statements between coverage counsel and insurance carrier may be relevant in cases alleging civil conspiracy.

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