In Walter v. Travelers Personal Ins. Co., 2013 U.S. Dist. LEXIS 72771 (M.D. Pa., May 22, 2013) (opinion by J. M.C. Carlson), the United States District Court for the Middle District of Pennsylvania held that "coverage counsel was, in fact, serving the client in an attorney-client capacity, and not in some other function such as a business advisor or claims adjuster." As a result, the court ruled that documents were properly withheld by an insurance company under the attorney-client privilege and work-product doctrine.