When the Document “Speaks for Itself” Deposing Witnesses About Written Agreements
Introduction: The Recurring Deposition Problem A familiar problem appears when an important document becomes the center of a deposition. The witness is shown a contract, policy, handbook, claim note, agency agreement, email, internal procedure, lease,…
Process Is Proof: Claims-Handling Discovery in Missouri First-Party UM/UIM Cases
Why the insurer’s “we just valued it differently” defense rarely survives a record built piece by piece. The most effective tactic the defense has in a first-party uninsured or underinsured motorist (UM/UIM) case is not about the wreck or the medicine.…
Proving the Insurer’s Breach of Fiduciary Duty in Missouri:A Discovery and Deposition Practice Guide
Who to depose, what to demand, and how to build the record that proves bad faith from the inside out Missouri Injury & Insurance Law | missouriinjuryandinsurancelaw.com Missouri Injury & Insurance…
Discovery in Missouri Insurance Coverage Litigation: Claim Files, Reserve Data, and the Work Product Doctrine
How to obtain the insurer’s internal records and overcome privilege objections Missouri Injury & Insurance Law | missouriinjuryandinsurancelaw.com Introduction Discovery in insurance coverage and bad faith litigation…