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,...
Deposition Outline: Breach of Contract – Liability Insurance Policy
Introduction This deposition outline suggests lines of inquiry to establish a breach of contract generally, and a breach of a liability insurance policy specifically....
Deposition Outline: Good Faith Reliance on Counsel
Attorney-Client Relationship Did you seek legal advice of any kind regarding plaintiff’s claim? Identify the attorney. Did you have an attorney-client relationship with this...