Siddall

*523 MEMORANDUM *

Appellant, Gary Lee Siddall (“Siddall”), filed this bad faith claim against Appellee, Allstate Insurance Company (“Allstate”) alleging Allstate unreasonably delayed resolution of his insurance claim. The district court granted Allstate’s motion for summary judgment; Siddall appeals.

I. Motion to Compel

Siddall alleges he had a “substantial need” for the mental impressions, conclusions, opinions, and/or legal theories of Allstate’s attorney. In analyzing this contention, it is important to discern the difference between the attorney-client privilege and the work product doctrine. Even if we agreed that Siddall had a substantial need for the requested documents, a substantial need does not, as a matter of law, provide a legal basis for piercing the attorney-client privilege. It can, however, provide the basis for obtaining material withheld under the work product doctrine. See Admiral Ins. Co. v. United States District Court for the District of Arizona, 881 F.2d 1486, 1494 (9th Cir.1989).

Although Siddall does not specifically refer to documents 1, 4, 6, 17, and 74, his arguments relate only to these because they were the only materials withheld by the district…