An insurance company may not protect itself from a motion to compel discovery by hiring an attorney to conduct investigations of claims. The plaintiff estate administrator, Dinesh Mehta, alleged that his wife was injured when she was crossing Main Street in East Hartford. The plaintiff requested underinsured-motorist benefits from the defendant insurance company. The plaintiff sued and requested discovery. The defendant insurance company claimed that certain documents were protected by the attorney-client privilege and the work-product doctrine. A party that invokes a privilege possesses the burden of proof, to establish each element of the privilege. The court reviewed the documents in camera. Many involved the e-mail correspondence sent to and from the defendant insurance company's claims specialist, who is an attorney. "An insurance company may not insulate itself from discovery by hiring an attorney to conduct ordinary claims investigations," pursuant to First Aviation Services Inc. v. Gulf Insurance Co., a 2001 decision of the District Court. Documents connected to an insurance claims investigation are privileged, only if they involve "truly confidential inquiries or responses to counsel concerning legal advice, rather than the insurance claims," pursuant to Reichhold Chemicals Inc. v. Hartford Acc. and Indem. Co., a 2000 decision of the Connecticut Superior Court. The attorney-client privilege does not apply to the claims specialist's work on the insurance company's claims investigation. An e-mail from the defendant insurance company's in-house counsel included legal advice and was entitled to privilege. An opinion about coverage that outside counsel provided after the complaint was filed also was entitled to privilege. Internal corporate communications, prepared after the complaint was filed and in contemplation of trial, were privileged. The court granted in part and denied in part the plaintiff's motion to compel.