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NOW COMES the defendant, Donald Laro, by his attorneys, Wiggin & Nourie, P.A., and files this objection to plaintiffs' motion to compel, and states as follows:

The parties are before the Court in a civil action concerning a telephone jamming operation said to have been engaged in by defendants during the November, 2002 elections. That jamming operation was intended to disrupt or frustrate a "Get Out The Vote" telephone effort on the part of the plaintiffs.

The plaintiff filed this petition pursuant to RSA chapter 91-A, the Right-to-Know Law, seeking disclosure of billing statements submitted to the Town of Durham by the law firm of Upton, Sanders & Smith. The Town has provided the plaintiff with redacted copies of the billing statements, showing only the dates when services were rendered, the time spent, and the total amount billed. The Town asserts its attorney-client privilege with respect to the remaining information contained in the bills.

At issue in plaintiffs' motion to compel are various documents that plaintiffs had sought from defendant New Hampshire Republican State Committee ("NHRSC") during discovery in this civil action. In earlier proceedings, the Court had entered various discovery orders. Plaintiffs assert that NHRSC has failed to comply with the discovery orders as entered by the Court. The items which presently appear to constitute the central focus of the plaintiffs' motion concern a report arising from an investigation of the underlying telephone jamming issues that had been conducted by legal counsel for defendant NHRSC, and its supporting documents. Counsel for NHRSC submits that the material at issue is protected by the attorney-client privilege as well as the attorney work-product privilege.

The court (Fauver, J.) issued an order on February 13, 2006, stating, in pertinent part: [T]he plaintiff requests "complete copies of any and all, documents received by you, your insurance company, or anyone on your behalf relating to the claims made by any and all parties in this case relating to the [subject accident]." The defendant objects, arguing this request is extremely overbroad and any letters and communications between the defendant and his counsel are subject to the attorney-client privilege. The court finds the insurance adjuster's claims file is not subject to the work product doctrine or the attorney-client privilege and may make any fact of consequence more probable or less probable than it would be without the evidence. Thus, the defendant is ordered to disclose the insurance adjuster's claims file to the plaintiff. With respect to the remaining portion of the plaintiff s request, the court finds it is overly broad, burdensome, and vague.