UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA SHREVEPORT DIVISION PRAISE TEMPLE CIVIL ACTION NO. 22-cv-5343 VERSUS JUDGE S. MAURICE HICKS, JR. EMPLOYERS MUTUAL CASUALTY CO MAGISTRATE JUDGE HORNSBY

MEMORANDUM ORDER

Before the court is Plaintiff's Motion to Compel (Doc. 22). The motion concerns the discoverability of policy reserves and related information in a case with allegations that the insurer acted in bad faith. Courts are divided over whether such information is relevant and/or protected work product. The undersigned agrees with Judge Cain’s decision in Langley v. Allied Trust,

(W.D. La. 2022). He held that policy reserves are relevant, not privileged, and pose no undue burden on the insurer. Accordingly, Plaintiffs motion is granted in part as to policy reserves and related documentation. However, to the extent that the reserve information was later adjusted based on input from Defendant’s trial counsel, that documentation or information may be withheld on the basis of work product. If this is done, Defendant must provide a detailed privilege log. Defendant is ordered to supplement its discovery responses within 14 days of this order. THUS DONE AND SIGNED in Shreveport, Louisiana on this 30" day of October, 2024. PN

U.S. Magistrate Judge