REQUESTS FOR PRODUCTION - INSURANCE COVERAGE

Requests

1. The policy(ies), declarations, endorsements, and amendments.
2. Underwriting file and application materials for the policy.
3. Claim file, including adjuster notes and internal communications.
4. Reservation of rights letters, denial letters, and coverage position letters.
5. Communications with the insured regarding the claim or coverage.
6. Communications with defense counsel, independent adjusters, or experts.
7. Reports, evaluations, or expert opinions regarding coverage.
8. Documents relating to policy conditions, exclusions, or limitations invoked.
9. Training materials or guidelines used for claim handling.
10. Documents supporting any asserted defenses to coverage.

Verification

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

______________________________
[RESPONDING PARTY NAME]
Date: [DATE]