Motions. 4.6.1 The Firm should evaluate the need for motion practice and consult with Citizens regarding the intent and expected outcome of each motion. In First Party claims, no motion shall be prepared, filed or served prior to approval from Citizens’ Claims & Litigation Legal Services or Citizens’ Litigation Specialist. In Third Party Liability actions, no motions shall be prepared, filed or served without prior consultation with Citizens’ Claims & Litigation Legal Services or Citizens’ Litigation Specialist. While no motion should be filed without first receiving approval from Citizens, failure to obtain approval from Citizens’ Claims & Litigation Legal Services prior to filing any of the following motions shall be deemed an automatic performance issue for the Firm:
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