LEGEND

To do a "search and replace" on a wordprocessor for the following terms and replace them with correct names.

&InsCo& means the client's insurance company.

&Plaintiff& means the plaintiff who sued the defendant/policyholder/client.

&Client& means the defendant/policyholder/client.

Atty, Bar #_

Tele:

Fax:

E-mail:

Attorneys for Plaintiff,

&Client&

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

&Client&

Plaintiff,

vs.

&InsCo& AND DOES 1-250,

Defendants.

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CASE NO.

Demand for Production, Inspection and Copying of Documents

Date for Production:

Complaint filed:

Trial Date:

Demanding Party:

Set Number:

Responding Party:

Pursuant to Code of Civil Procedure § 2020.010 et. seq, the demanding party identified above demands that the responding party identified above serve a verified response to this notice and produce within 30 days from the date of service of this notice for inspection and copying the following items and categories of documents and electronically stored information. Electronically stored information shall be produced in the form of a thumb drive readable on a personal computer. The documents and electronically stored information shall be produced at [place] on [date and time]. This notice is being served on all parties who have appeared in the action.

Demand for Production #1:

Policy of insurance bearing policy number __ , including all endorsements issued after the date of issue and all forms identified in the Declarations.

Demand for Production #2:

&InsCo&'s entire &Plaintiff& vs. &Client& claim file, including all documents, notes and work papers (including copies of all correspondence) which reasonably pertain to each claim in such detail that pertinent events and dates of the events can be reconstructed and the insurer's actions pertaining to the claim can be determined, acknowledgments of receipt of all notices of claims, the amounts of claims accepted or denied, and information obtained in a telephone conversation or personal interview as required by Cal. Code Regs. § 2695 et. seq.

Demand for Production #3:

&InsCo&'s claims adjusting manual.

Demand for Production #4:

All of &InsCo&'s licenses, certificates of authority from the California Insurance Commissioner to transact business in the State of California or with California residents and certificates made under penalty of perjury that person employed or authorized by &InsCo& to conduct an investigation of a claim on behalf of &InsCo& has read and understands insurance regulations maintained at &InsCo&'s principal place of business.

Demand for Production #5:

&InsCo&'s written standards for prompt, fair and equitable settlements and written standards for the prompt investigation and processing of claims adopted and communicated to all persons employed or authorized by &InsCo& to conduct an investigation of a claim on its behalf.

Dated: December , 2016

By:______________________________

Attorney for Plaintiff, &Client&