In the Matter of the Liquidation of Integrity Insurance Company

Summary

The Supreme Court of New Jersey held that the deliberative process privilege does not apply to the Commissioner of Insurance when acting as liquidator of an insolvent insurer, and therefore the documents sought by the reinsurers are discoverable subject to an in‑camera balancing of confidentiality interests. The Court also clarified that N.J.R.E. 515 is a distinct privilege and not automatically applicable in this context, and it affirmed the Appellate Division’s order remanding for further proceedings.