In a wrongful discharge case under the Illinois Workers’ Compensation Act, Larry Holland’s evidence against his former employer, Schwan’s Home Service, included the claim file of Schwan’s insurance carrier, Hartford Insurance Co., and Hartford’s third-party administrator, Specialty Risk Services. The file contained notes from Joan Kantor, an SRS adjuster who did not testify at trial, about her conversations with Schwan’s agents and employees. Objecting, Schwan’s argued that 1) …