On April 27, 2018, Spotsylvania Circuit Court opined that the offending motorist’s statement taken by his State Farm insurance adjuster after the two-car crash was discoverable, not privileged work product, as “made to insurance agents in the regular course of business not in preparation for litigation”. The 4-page letter opinion issued in the vehicle accident case of Monterrozo v. Sandridge, No. CL15-1224. It adopted the so called “bright-line rule” test, based on whether the statement was given before plaintiff gave notice of claim and before defendant retained legal counsel.