Category: Discovery

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 Fiduciary Duty

Following is a list of code words to conveniently customize the following deposition outline by using the “find and replace” function of a wordprocessor. &Client& means...

Deposition Outline: PMQ – Insurer Duties

The following deposition outline is hyper-technical, exhaustive, and lengthy. Attorneys intending to depo insurance claims personnel or PMQ may want to review this document,...
Please enter your email address in order to view this page.
Your email address will not be sold to or shared with third parties.
DutytoDefend.com