A New York trial court ordered insurer OneBeacon to turn over its claims handling documents created during the pendency of the coverage action, which were relevant to Estee Lauder's bad faith claim against the insurer. Estee Lauder, Inc. v. OneBeacon Ins. Grp., 213 N.Y. Misc. LEXIS 1550, 2013 N.Y. Slip Op. 30762 (April 15, 2013). In this coverage action, Estee Lauder sought coverage from OneBeacon for underlying environmental claims. After the appellate court held that OneBeacon had to defend Estee Lauder and pay all reasonable defense costs, Estee Lauder submitted defense cost invoices to the insurer. The insurer took nearly two years to pay the covered costs. Estee Lauder amended its complaint to add a bad faith claim related to this lengthy delay, and sought documents related to the insurer's claims handling during this period. OneBeacon claimed the documents were protected by the attorney-client privilege and attorney work product doctrine because they were created after the initiation of the coverage action. The trial court disagreed, correctly recognizing that payment of covered defense costs is an ordinary part of an insurer's business.