This is the definitive case management guide, written to help both policyholders' and insurers' attorneys save time and money in complicated insurance coverage cases. It details the ways to formulate and implement case management procedures with a series of orders covering pleadings, amendments, early motions, and hearings. There are also provisions on the scope and conduct of interrogatories, document requests, depositions, and other discovery devices. Valuable techniques for efficiently presenting the issues to court and jury are also provided.
Authoritative answers are given for such questions as:
* What issues should a comprehensive Case Management Order address?
* How can written and deposition discovery be conducted more efficiently and at lower costs?
* What issues should be addressed in settlement documents?
* How can motion practice be streamlined without sacrificing the parties' right to be heard?
* Which amendments to the Federal Rules must be considered in formulating a case management plan?
* How can the case be "phased" to make it more manageable?
* What case management techniques improve handling complex insurance coverage litigation cases?
* And more.
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