Common use of DISCOVERY / MOTION PRACTICE Clause in Contracts

DISCOVERY / MOTION PRACTICE. 4.1 Focused / Purposeful Assignments from Citizens are to be handled in a proactive manner. As a result, early investigation and discovery are expected and necessary. It is recognized that many cases will not be tried to conclusion; therefore early discovery should be targeted, fact finding, and relevant to further the litigation position in the matter and assist in both early settlement activities as well as trial if settlement is not reached. Any discovery, including depositions, conducted on behalf of Citizens or Citizens’ insured shall be focused and purposeful in light of the needs and issues associated with the specific matter.