In a dispute between the excess and primary liability insurance carriers of a common insured based upon the primary insurer’s alleged breach of the duty to defend the common insured, the U.S. District Court for the Eastern District of Louisiana (the “Court”) ordered the production of the complete personnel files for claims adjusters involved in the claims process for the case at issue. The excess carrier, which sought production of the claim adjuster personnel files asserted that the personnel files were relevant because: 1) the primary carrier’s guidelines stated that staff counsel is not able to make decisions regarding the claims without first obtaining authority from the claims department, and 2) the adjusters’ experiences and backgrounds were relevant to determining whether they were able to make prudent decisions regarding the underlying claim. The primary carrier argued that it should not be required to produce personnel files because the files could contain sensitive information, the production request was not narrowly tailored, and the excess insurer could obtain the information it seeks when it deposes its employees. The Court found that the personnel files may contain relevant and highly probative information concerning the experiences and backgrounds of the adjusters that handled the claim with staff counsel during the underlying suit. However, given the potential sensitive nature of such files, the Court ordered an in camera inspection of those files. See RSUI Indemnity Company v. American States Insurance, Case No. 2:12-cv-02820 (U.S.D.C. E.D. La. Feb. 18, 2015).