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 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.
- Typical policyholder requests
- Typical insurer requests
- Recurring issues
- Requests that lack "reasonable particularity"
- Objecting to requests for production
- Avoiding boilerplate objections and objecting with "specificity"
- Identifying what is being produced vs. what is being withheld
- Identifying a time for production
- 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?
Royce F. Cohen
Ms. Cohen provides legal consulting / expert testimony concerning eDiscovery, Records and Data Management, Information... | Read More
Ms. Cohen provides legal consulting / expert testimony concerning eDiscovery, Records and Data Management, Information Governance, data theft/loss, and high-risk data sources. She navigates complex legal landscapes with discretion, delivering strategic guidance and invaluable insights to clients. Ms. Cohen undertakes intricate data-related challenges and delivers impactful solutions.Close
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
As a Principal at Berman Fink Van Horn, Mr. Kahn advises a broad range of clients in business disputes, including in trial and appellate courts. His complex commercial litigation and appellate practice focuses on business disputes, including contractual matters and business torts, insurance recovery, fraud, deceptive trade practices, partnership and shareholder matters, banking and consumer finance cases, real estate, and trade secret and noncompete litigation. Jeremy handles his clients’ matters from the start of the dispute, through litigation, and, if necessary through the appellate process. Mr. Kahn has successfully handled numerous appeals in both state and federal appellate courts.Close
Jonathan E. Meer
Mr. Meer is highly experienced in the area of insurance coverage, including monitoring and coverage determinations. He... | Read More
Mr. Meer is highly experienced in the area of insurance coverage, including monitoring and coverage determinations. He maintains a particular concentration in coverage for directors and officers (D&O), with an emphasis on the growing area of D&Os in cannabis companies; professional errors and omissions (E&O); lawyers (LPL); employment practices; and cyber liability programs.Close