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investigation of a claim was a privileged communication protected from discovery underIll. S. Ct. R. 201(b)(2)); Koch v. Miller, 49 Ill. App. 2d 251, 257 (5th Dist. 1964) (the courtheld that a written statement signed by the insured on the back of an accident reportregarding an auto collision was privileged against discovery because the report andstatements were given to the insurance adjuster as an agent to be made available to anattorney that may have been selected to defend any action brought against the insured);Ryan, 30 Ill. 2d at 461 (the Illinois Supreme Court held that the written statement madeby an insured to the investigator of the insurance company, which was later placed inthe insurance file and given to an attorney who was defending the insured on criminalcharges, retained its privilege); Claxton, 201 Ill. App. 3d at 237-38 (the written statementmade by the director of the employer to the employer’s insurer was not privilegedagainst discovery because the director was not part of the corporate control group;however, had the director been a member of the control group, he would not have hadto disclose the statements otherwise covered by attorney-client privilege simplybecause he actually witnessed the incident at issue). Otherwise, such statements aregenerally discoverable.3. Does your state recognize a self-critical analysis privilege?Illinois does not recognize a self-critical analysis privilege. Harris v. One Hope United,Inc., 377 Ill.Dec. 851, 2 N.E.2d 1132, 2013 Ill.App. LEXIS 869 (1st Dist. 2013). The loneexception is in the context of our Medical Studies Act, 735 ILCS 5/8-2101, which has asits purpose to ensure the effectiveness of professional self-evaluation, by members ofthe medical profession, in the interest of improving the quality of health care. TheMedical Studies Act is premised on the belief that, absent a statutory peer reviewprivilege, physicians would be reluctant to sit on peer review committees and engage infrank evaluations of their colleagues.

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