Langdon (P) sought production of an insurance adjustor's files that were prepared prior to commencement of suit and the involvement of an attorney for Champion (D). The matter involved a personal injury action by P against D. D's insurance company and its adjuster became aware of the claims of P and D gave a recorded statement to his insurance adjuster. This was done before the involvement of an attorney for D. P requested production of those documents and D objected on grounds of work product and attorney-client privilege. The trial court refused, and P appealed.