FORM INTERROGATORIES - INSURANCE COVERAGE

Instructions

1. Answer each interrogatory separately and fully in writing under oath.
2. If you object, state the grounds and answer the non-objectionable portion.
3. Identify documents supporting each response.

Interrogatories

1. Identify all policies that may provide coverage for the claim at issue.
2. Identify the policy periods, limits, and relevant endorsements.
3. Identify all persons involved in the claim investigation and decision-making.
4. Describe the basis for any reservation of rights or denial of coverage.
5. Identify all communications with the insured regarding coverage.
6. Identify all communications with defense counsel, independent adjusters, or experts.
7. Describe any coverage position changes and the dates of each change.
8. Identify any policy conditions you contend were not satisfied.
9. Identify all documents supporting your coverage position.
10. Identify any prior claims or losses you contend are relevant to coverage.

Verification

text
I declare under penalty of perjury that the foregoing answers are true and correct.

______________________________
[RESPONDING PARTY NAME]
Date: [DATE]