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Recurring Document Requests in Insurance Litigation: Drafting Reasonable Requests and Raising Sustainable Objections

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, August 15, 2023

Recorded event now available

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This CLE webinar will offer insurance litigators for plaintiff or defense practical ways to make drafting and responding to perennial document requests less onerous and more efficient. Insurer counsel, plaintiff counsel, and a document-production expert will discuss in the specific context of insurance litigation what Federal Rules of Civil Procedure 26 and 34 require and prohibit and propose solutions to several seemingly intractable discovery problems.


Whenever coverage is litigated, policyholders and insurers request a predictable set of written materials hoping to establish or refute the proposed meaning of the policy or to demonstrate how claims were or were not properly addressed.

Typical policyholder requests include the claim and underwriting files, underwriting manuals, drafting histories of policy language, and documents interpreting that language, while insurers often request production of all decisions, documents, and communications from the insurer that the policyholder contends supports its position. Both sides have an interest in limiting access to information helpful to the other side.

Requests are often met with equally predictable responses that do little to help resolve the case. Both sides need to know how to better draft reasonable and precise requests and how to correctly raise sustainable objections and avoid boilerplate and vague responses.

Listen as the panel dives deep into what the FRCP requires in insurance litigation and novel ways to provide responses and objections that comply with the rules but retain sufficient flexibility to address the fluidity of discovery.



  1. Typical policyholder requests
  2. Typical insurer requests
  3. Recurring issues
    1. Requests that lack "reasonable particularity"
    2. Objecting to requests for production
      1. Avoiding boilerplate objections and objecting with "specificity"
      2. Identifying what is being produced vs. what is being withheld
      3. Identifying a time for production
    3. Privilege considerations


The panel will discuss these and other key issues:

  • Is it helpful to know why particular documents are being requested?
  • What are the best strategies for drafting requests with reasonable particularity?
  • What role does the attorney-client privilege play in shielding disclosures?
  • How does AI affect privilege?


Cohen, Royce
Royce F. Cohen

Veritas RFC

Ms. Cohen provides legal consulting / expert testimony concerning eDiscovery, Records and Data Management, Information...  |  Read More

Kahn, Jeremy
Jeremy L. Kahn

Berman Fink Van Horn

As a Principal at Berman Fink Van Horn, Mr. Kahn advises a broad range of clients in business disputes, including in...  |  Read More

Meer, Jonathan
Jonathan E. Meer

Wilson Elser

Mr. Meer is highly experienced in the area of insurance coverage, including monitoring and coverage determinations. He...  |  Read More

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