Deposition – Summary of Statutes
Right to discovery: Code Civ. Proc. §2017.210. A party may obtain discovery of insurance; the identity of the insurer, nature and limits of the...
Requests for Admission – Summary of Statutes
Code Civ. Proc. § 2033.010 Any party may obtain discovery by a written request that any other party to the action admit the genuineness...
Requests for Admission to Insurer
Pursuant to Code of Civil Procedure § 2033.010 et. seq, the demanding party identified above demands that the responding party identified above admit the...
Deposition Outline: Claim Agent
USE NOTES: An object of deposing insurance claims agents is to establish that they make bad decisions, and that they were made knowingly or...
Demand to Produce Documents to Insurer
Click below to download a model Demand for Production of Documents from a policyholder to an insurer for the policy, the insurer’s claim file, claims...
Deposition Outline: Breach of Attorney’s Fiduciary Duty
This deposition outline suggests lines of inquiry to establish a breach of fiduciary duties by dependent counsel. [Footnotes refer to legal authority supporting the...
Deposition Outline: PMQ – Insurer Duties
This model deposition outline is limited in scope to examination of the person most knowledgeable of &InsCo& to determine the contents of the policy,...
Deposition Outline: Breach of Contract – Liability Insurance Policy
Introduction This deposition outline suggests lines of inquiry to establish a breach of contract, specifically a breach of a liability insurance policy. [Bracketed information refers...
Deposition Outline: Good Faith Reliance on Counsel
This deposition outline suggests lines of inquiry to establish whether the insurer is asserting a valid a defense to bad faith of good faith...