Don’t trust insurance companies. One of the first things they will do in a case where there may be exposure - is to take the statements of witnesses. Eye witnesses to be precise.
While it is good to take a statement in a timely manner. It is bad when the interviewer messes with the memory of the eye witness or skews what they say. Insurers will never turn over their work product of interviewing these witnesses. Though they must turn over any interview of the plaintiff who unknowingly agreed to be interviewed before hiring a lawyer (shudder).
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