Discovery Requests in Insurance Litigation: Interrogatories, Production of Documents, Admissions of Fact, and More

Propounding or Responding to Discovery Requests After Amendments to Rules 26(b) and 34(b)

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, April 5, 2017
Recorded event now available

This CLE webinar will discuss discovery practice and strategy in insurance litigation in the wake of the Dec. 2015 amendments to the Federal Rules of Civil Procedure. The panel will explore crafting discovery requests that are sufficiently specific and likely to withstand burden and proportionality challenges. The panel will also discuss how to object to Rule 34 requests with specificity and how to respond to early requests for production within a “reasonable time,” which the 2015 amendments also require.


In the wake of the 2015 amendments to Rule 26(b) of the Federal Rules of Civil Procedure, insurance litigators are increasingly raising proportionality arguments in discovery. Courts have emphasized that parties must rein in overly broad discovery requests.

Litigators must now be prepared to justify any request for discovery that goes beyond the direct circumstances that led to the insurance claim and damages sought. Interrogatories, requests for production of documents, requests for admissions, and third-party subpoenas for information may be narrowed or quashed if the burden or expense of producing the information outweighs its likely benefit.

Knowing how to draft discovery requests that are likely to withstand burden and proportionality challenges as well as how to craft objections to broad discovery requests is critical for insurance litigators. This includes understanding how to object to Rule 34 requests with specificity and how to respond to early requests for production within a “reasonable time,” which the 2015 amendments also require.

Listen as our authoritative panel discusses how courts are interpreting and applying the 2015 amendments to the Federal Rules of Civil Procedure and best practices for insurance litigators for drafting and responding to discovery requests.


  1. Brief overview of 2015 amendments and their requirements
  2. Considerations for drafting discovery requests
  3. Strategies for responding/objecting to discovery requests


The panel will review these and other key issues:

  • When drafting discovery requests, what are key considerations to ensure that the requests are in line with the proportionality standard?
  • When responding to early requests for production, how specific must insurance litigators be in their objections? What constitutes “reasonable time” for producing information?
  • What guidance does case law provide on determining when the burden or expense of obtaining discovery outweighs the likely benefit?


Sarah R. Anchors, Partner
Quarles & Brady, Phoenix

Ms. Anchors practices general commercial litigation, with a focus on lender liability, consumer protection statutes, and insurance policyholder representation. She assists insurance policyholders in obtaining coverage for claims and works on bad-faith claims. Recently, she has presented on the emerging field of insurance coverage for data breaches and cybersecurity risks. Additionally, she has experience representing lenders and businesses in eminent domain actions.

Tomas M. Thompson, Partner
Vocke Law Group, Chicago

Mr. Thompson has significant experience representing insurers and reinsurers in complex coverage matters, class actions, regulatory investigations, and reinsurance arbitrations. His broad range of experience spans litigation and counseling on cutting edge insurance, accounting, and technology issues. In the insurance industry, he handles a wide range of matters for property and casualty insurers and reinsurers, including disputes arising from professional liabilities, extra-contractual liabilities and bad faith claims, surplus lines, retrospectively-rated and other loss-sensitive programs, and off-shore and on-shore captives. He advises on broker and MGA disputes, bankrupt insureds and insolvent insurers, excess insurers and drop down issues, rate regulations, statutory accounting, and aggregation issues. 


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Program Materials

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I thought it was very informative and helpful to have different perspectives on the issues.

Matthew Siegel

Cozen O'Connor

Insurance Law Advisory Board

John Broghammer


Greve Clifford Wengel & Paras

Tred Eyerly


Damon Key Leong Kupchak Hastert

John D. Green


Farella Braun + Martel

Alan P. Jacobus

Lafayette & Kumagai

William E. Kelley, Jr.


Drewry Simmons Vornehm

William O. Krekstein


Timoney Knox

Jay M. Levin

Principal and Chair of the Insurance Recovery Practice

Offit Kurman

Peter J. Mintzer


Selman Breitman

Barry S. Neuman


Whiteford Taylor Preston

Andrew G. Wanger


Clyde & Co.

Britton D. Weimer


Weimer & Weeding

Sandra I. Weishart


Hinshaw & Culbertson

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