Woo v. Fireman's Fund Insurance

*484¶1 At issue is an order sealing insurance company claims manuals that were used as exhibits at trial of a bad faith claim. The trial court erred in concluding that the manuals deserved protection as a trade secret. They are not novel, and reasonable efforts were not made to protect their secrecy.

Becker, J. —

¶2 This lawsuit began when Robert Woo, a dentist, played an embarrassing practical joke on an employee while she was under anesthesia during a dental procedure. The employee sued Woo, alleging intentional torts as well as medical negligence. At the time of the incident, Fireman’s Fund was…