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Lund v. St. Paul Fire & Marine Insurance Co.2/11/2002
Notes dated 12/02/98 and 12/04/98. Produce unredacted.
00334 Carol Crews Note re "Plan of Action with Target Dates," approximate date 12/31/98. Produce unredacted.
00335 Email to Kim Mobley from Carol Crews dated 12/31/98. Redact material regarding reserves. Produce remainder of page.
00336 Message regarding claim review meeting dated 12/18/98. Produce unredacted.
00337 Fax Transmittal cover sheet dated 12/17/98 from Carol Crews to Colin Reid/Jodi McGee. Produce unredacted.
00338 Copy of WC statutes. Produce unredacted.
00339 Transmission Verification Report dated 12/17/98. Produce unredacted.
00340 Copy of WC statutes (identical to 00338). Produce unredacted.
00292 Handwritten note dated 12/22/98. Work product. Do not produce.
00255 Handwritten "Memo to file" on Speed Letter form dated 2/19/99. Produce unredacted.
00256 Identical to 00255. Produce unredacted.
00257 Identical to 00255 and 00256. Produce unredacted.
00252 Diary File Notes bearing date 3/15/99, reflecting entries dated 12/28 and 12/29/98 and 1/15/99. Redact entries regarding reserves. Produce remainder unredacted.
00250 Diary File Notes bearing date 3/15/99, reflecting three entries dates 1/15/99. Work Product. Do not produce.
00248 Diary File Notes bearing date 3/15/99, reflecting entry made 2/2/99. Produce first sentence of entry, but redact remaining sentences of entry as work product, including mental impressions of claims adjuster regarding dispute.
00246 Diary File Notes bearing date 3/15/99, reflecting entries made 2/2/99. Produce unredacted.
00244 Diary File Notes bearing date 3/15/99, reflecting entries made 2/2, 2/5/, 2/23, 3/5, and 3/9/99. Redact 3/9/99 entry regarding reserves. Otherwise, produce unredacted.
00223 Untitled, undated document with reference to "Plan of Action," apparently prepared by Cathy Andersen. Produce unredacted.
00047 Handwritten notes on "Claim Progress" form with entries dated 2/9/99 through 2/7/01. Produce, but with entry for 4/19/99 regarding reserves redacted. (Note that redaction already accomplished with white tape in copy provided to court, but writing underneath still visible on that copy.)
00048 Evidently continuation of "Claim Progress form," showing no entries. Produce unredacted.
00049 Handwritten notes on "Claim Progress" form with entries dated 10/14/98 through 11/30/98. Produce unredacted.
00050 Handwritten notes on "Claim Progress" form with entries dated 12/21/98 through 1/8/99. Produce, but redact 12/21 entry re reserves if redaction desired by respondent.
00051 Handwritten notes on "Claim Progress" form with entries dates 11/30 through 12/15/98. Produce unredacted.
00052 Evidently continuation of "Claim Progress form," showing no entries. Produce unredacted.
00053 Handwritten notes on "Claim Progress" form with entries dated 9/28 through 10/13. Produce unredacted.
00054 Evidently continuation of "Claim Progress form," showing no entries. Produce unredacted.
Respondent must comply with this Order on or before March 8, 2002. Respondent must provide legible copies to claimant's counsel.
SO ORDERED.
DATED in Helena, Montana, this 1st day of March, 2002.
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