Republic Insurance Co. v. Davis
Justice Gammage concurs with parts I, II, III-A, most of III-B, and IV of the majority opinion, acknowledging the need for Republic to object to a special master's report, the applicability of the 'offensive use' exception to attorney-client privilege, and the scope of party communications privilege. However, he dissents from the majority's imposition of stricter factors for offensive-use waiver compared to federal standards. He strongly disagrees with the majority's interpretation of a Declaratory Judgment Act counterclaim as not seeking 'affirmative relief,' arguing that such actions can indeed constitute 'offensive use' under the *Ginsberg* doctrine, particularly when used to preempt liability. Gammage concludes that the attorney-client privilege should be waived for certain documents based on offensive use and would have denied the petition for writ of mandamus in its entirety. Justice Doggett joins this concurring and dissenting opinion.