Sequoia Books, Inc. v. Illinois

According to the advisory committee notes to Rule 26(b)(3), “ ‘materials assembled in the ordinary course of business ... or for other nonlitigation purposes are not under the qualified immunity provided by [the rule].’ ” | risk management documents relating to pending product liability suits used in business planning not work product | purpose of takings clause is to “protect the claimant’s reasonable, often investment-backed expectations, rather than inchoate unilateral expectations” | reserve information is discoverable where claim of bad faith is made against defendant-insurer