Category: Model Documents

Downloadable draft documents for readers to adapt and use

Additional Cause of Action – Bad Faith

VERIFIED COMPLAINT &BLANK& CAUSE OF ACTION                                         (Bad Faith Against &InsCo& and Does 1-50) &Client& realleges foregoing paragraphs 1 through &Blank& and incorporate them...

Additional Cause of Action – Breach of Contract

VERIFIED COMPLAINT &BLANK& CAUSE OF ACTION                                 (Breach of Contract Against &InsCo& and Does 1-50) &Client& realleges foregoing paragraphs 1 through &Blank& and incorporate...

Ethical Compliance Questionnaire

USE NOTES: This Ethical Compliance Questionnaire asks challenging questions to dependent counsel when an insurer has reserved its rights to deny coverage. Dependent counsel...

Verified Complaint – Additional Causes of Action

VERIFIED COMPLAINT 3. Breach of Contract 4. Bad Faith 5. Breach of Fiduciary Duty 6. Legal Malpractice THIRD CAUSE OF ACTION                                 (Breach of...

Please Allocate for Buss Claim

MODEL LETTER Maybe – Please Allocate for Buss Claim   USE NOTES: This letter may be appropriate if the insurer has sent a reservation...

Conflict of Interest Waiver Request

USE NOTES: The insurer previously sent a reservation of rights letter and declined to withdraw or limit it. Dependent counsel seeks to comply with...

2860 Qualifications

 USE NOTES: This Model Letter assumes that the insurer has reserved rights to deny coverage, hired its lawyer, and assumed control the policyholder’s defense....

Presigned Verification Forms

MODEL LETTER Presigned Verification Forms  USE NOTES: The insurer previously sent a reservation of rights letter and declined to withdraw or limit it. Adapt...

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,...
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