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Library of California Insurance Defense Forms

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R. Wardell Loveland, Randolph S Hicks, Richard G. Grotch, Hyon M. Kientzy


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Library of California Insurance Defense Forms is a library of more than 180 model documents. Included are author practice tips and a CD of forms, allowing for easy drafting and editing of Word documents. Library of California Insurance Defense Forms  is designed to guide attorneys through the process from preliminary matters through ADR and trial, with sample letters, demands,  pleadings, motions, certifications, interrogatories, settlement agreements, briefs and other trial documents. Written by R. Wardell Loveland, Randolph S. Hicks, Richard G. Grotch, and Hyon M. Kientzy,the book is reflective of the expertise accrued through years of successful litigation.

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  • Availability: Available
  • Brand: The Recorder (CA)
  • Product Type: Books
  • Edition: 1
  • Page Count: 500
  • ISBN: 978-1-57625-580-3
  • Pub#/SKU#: CAIDF13
  • Pub Date: 09/30/2013
  • CDs: 1

Author Image
  • R. Wardell Loveland

Mr. Loveland is a Member of the law firm of Coddington, Hicks & Danforth in Redwood City, California.  His practice involves a broad spectrum of litigation and insurance services. In the area of litigation, Mr. Loveland represents defendants in class action suits, insurers in insurance fraud and bad faith actions, and insureds in personal injury actions. Mr. Loveland also advises and defends insurers in regulatory matters, provides advice and training to claims and general counsel personnel, and advises general counsel of insurance companies regarding business practices.


Mr. Loveland has represented insurers since the day he was admitted to practice in 1987. He has tried to verdict numerous bad faith matters, many involving fraud, and has successfully argued several insurance cases before appellate courts. He has drafted proposed legislation, regulations in the areas of claims handling and representation of insureds. He has been an invited speaker on the topics of insurance fraud and bad faith over 40 times in his career.


Mr. Loveland graduated with an A.B. in English from Princeton University in 1981. He obtained his law degree from Boston College Law School in 1986. Mr. Loveland has been with Coddington, Hicks & Danforth since 1989.




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  • Randolph S Hicks

Mr. Hicks has spent his entire legal career at the firm of Coddington, Hicks & Danforth in Redwood City, California.  He handles a wide variety of complex tort, commercial and insurance litigation and has tried numerous cases to jury verdict in both the state and federal courts.  His practice focuses on aviation, insurance coverage, insurance bad faith, product liability and business litigation. 


As an adjunct to his litigation practice, Mr. Hicks advises and trains insurers and their attorneys on coverage and insurance claims handling issues.  He has written several articles on insurance coverage and insurance bad faith issues and has spoken at many insurance and defense attorney sponsored seminars and events.


For many years, Mr. Hicks has been recognized as a California Super Lawyer, an honor bestowed on the top five percent of California attorneys.  He has been elected to be a member of the American Board of Trial Advocates.  For six years, he served on the Board of Directors of the Association of Defense Counsel of Northern California and Nevada, and for three years was the co-editor of the Defense Comment magazine.  He also served for four years on the Complex Civil Litigation Committee of the San Mateo County Superior Court which designed and implemented the court’s Complex Civil Litigation Program.




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  • Richard G. Grotch

Mr. Grotch is a Member of the law firm of Coddington, Hicks& Danforth in Redwood City, California. Although he represents clients in a wide array of personal and business disputes, Mr. Grotch specializes in aviation, products liability and civil rights litigation as well as appellate matters. Particularly in connection with legal issues arise in airline claims and litigation, Mr. Grotch serves as national counsel for a number of major domestic air carriers, representing clients, assisting in airline litigation throughout the nation and in foreign jurisdictions and provides counsel and guidance in matters of policy and risk management.

Mr. Grotch graduated with an A.B. in History and Political Science from the University of California, Davis in 1983.  He obtained his law degree from the University of California Hastings College of the Law in 1986. Mr. Grotch has been with Coddington, Hicks & Danforth since 1987.



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  • Hyon M. Kientzy

Ms. Kientzy is a Member of Coddington, Hicks & Danforthin Redwood City, California.  Her practice focuses primarily upon insurance related matters, ranging from coverage, bad faith, advice and counseling upon best practices, and regulatory compliance.  Over the last decade, she has developed a sophisticated practice defending complex/class actions involving allegations of institutional bad faith, fraud, and unfair business practices.  She has been involved in numerous bench and jury trials and matters before the Courts of Appeal.  Ms. Kientzy has also given many seminars and presentations to attorneys and other professionals on topics pertaining to claims handling and regulatory matters.

Ms. Kientzy received her undergraduate degrees in Political Science and History from UCLA in 1997 and received her J.D. from the Santa Clara University School of Law in 2000.  She has been with Coddington, Hicks & Danforth her entire career.


 

Chapter 1: Preliminary Matters Correspondence

1-000   Chapter 1 Practice Tips

1-001   Letter Acknowledging Receipt of Assignment from Insurer/Client

1-002   Letter Advising Insured of Representation

1-003   Letter To Client/Insured Regarding Acceptance of Service of Complaint

1-004   Letter Protecting Time To Respond To Complaint

1-005   Demand for Preservation of Evidence, Including ESI

1-006   Letter Scheduling Initial Office Conference Pleadings

1-007   Stipulation Extending Time To Respond To Complaint

1-008   Standard Answer To Unverified Complaint

1-009   Answer To Verified Complaint

1-010   Answer To Federal Court Complaint

1-011   Standard Affirmative Defenses

1-012   Verification – Corporate

1-013   Verification – Individual

1-014   Verification – Attorney

1-015   Cross-Complaint for Indemnity

1-016   Answer To Cross-Complaint

1-017   Notice of Petition To File Complaint In Intervention

1-018   Memorandum of Points and Authorities In Support of Petition To File Complaint In Intervention

1-019   Declaration In Support of Petition To File Complaint In Intervention

1-020   Complaint In Intervention

1-021   Notice of Motion for Leave To Amend Answer

1-022   Memorandum of Points and Authorities In Support of Motion for Leave To Amend Answer

1-023   Declaration In Support of Motion for Leave To Amend Answer

1-024   Motion To Quash for Lack of Jurisdiction

1-025   Motion To Quash Summons for Lack of Proper Service

1-026   Memorandum of Points and Authorities In Support of Motion To Quash

1-027   Declaration In Support of Motion To Quash

1-028   Motion To Stay Or Transfer Action (Convenience of Witnesses)

1-029   Stipulation To Consolidate Actions

1-030   Motion To Consolidate Actions

1-031   Memorandum of Points and Authorities In Support of Motion To Consolidate Actions

1-032   Suggestion of Stay (Bankruptcy)

1-033   Motion for Relief from Default

1-034   Declaration in Support of Motion for Relief from Default

1-035   Motion for Change of Venue

1-036   Memorandum of Points and Authorities In Support of Motion for Change of Venue

1-037   Stipulation and Order Changing Venue

1-038   Stipulation Limiting Damages and Defeat Diversity Jurisdiction

1-039   Notice of Removal

1-040   Notice To Superior Court of Removal of Case To Federal Court

1-041   Jury Demand

1-042   Certificate As To Interested Entities

1-043   Notice of Related Cases

1-044   Federal Court – Joint Case Management Conference Statement

 

Chapter 2: Attorneys

2-000   Chapter 2 Practice Tips

2-001   Association of Attorneys

2-002   Notice of Unavailability of Counsel

2-003   Declaration To Be Relieved As Counsel

2-004   Motion To Disqualify Counsel

 

Chapter 3: General Materials Correspondence

3-000   Chapter 3 Practice Tips

3-001   Initial Case Analysis/Evaluation

3-002   Deposition Report

3-003   Report On Discovery Responses Pleadings

3-004   Proof of Service – Personal/Mail/Express Courier/Fax/Electronic

 

Chapter 4: Preliminary Motions Attacking The Pleadings

4-000   Chapter 4 Practice Tips

4-001   Notice of Demurrer

4-002   Demurrer

4-003   Memorandum of Points and Authorities In Support of Demurrer

4-004   Notice of Motion To Strike

4-005   Memorandum of Points and Authorities In Support of Motion To Strike

4-006   Federal Motion To Dismiss

4-007   Notice of Special Motion To Strike(Anti-Slapp)

4-008   Memorandum of Points and Authorities In Support of Special Motion To Strike

 

Chapter 5: Dispositive Motions

5-000   Chapter 5 Practice Tips

5-001   Notice of Motion for Summary Judgment/Summary Adjudication

5-002   Memorandum of Points and Authorities In Support of Motion for Summary Judgment/Summary Adjudication

5-003   Separate Statement of Undisputed Material Fact

5-004   Declaration In Support of Motion for Summary Judgment

5-005   Objections To Evidence

5-006   Response To Separate Statement of Undisputed Material Facts

5-007   Proposed Order After Uncontested Tentative Ruling

5-008   Proposed Order After Contested Tentative Ruling

5-009   Judgment After Summary Judgment/Dispositive Motion

5-010   Notice of Entry of Judgment Or Order

 

Chapter 6: Discovery Correspondence

6-000   Chapter 6 Practice Tips

6-001   Letter To Insured/Client Forwarding Discovery and Requesting Information for Drafting of Responses

6-002   Letter To Opposing Counsel Confirming Extension of Time To Respond To Discovery

6-003   Letter To Opposing Counsel Requesting Overdue Discovery Responses

6-004   Letter To Counsel Regarding Scheduling/Re-Scheduling of Deposition

6-005   Letter To Insured/Client/Witness Regarding Scheduling of Deposition

6-006   Letter To Subpoenaed Deponent Requesting Acceptance of Service of Subpoena by Mail

6-007   Letter To Custodian of Records Regarding Failure To Comply With Subpoena

6-008   Letter To Counsel Regarding Scheduling of Physical/Mental Examination

6-009   Letter To Doctor Regarding Scheduling of Examination of Plaintiff

6-010   Letter To Opposing Counsel To Meet and Confer Regarding Failure To Provide Discovery Responses

6-011   Letter To Opposing Counsel To Meet and Confer Regarding Inadequate Discovery Responses

6-012   Letter To Opposing Counsel Or Claimant With Request for Medicare Information and Information from CMS

6-013   Medicare Form Attachment Pleadings

6-014   Special Interrogatories – Contention

6-015   Special Interrogatories – Wrongful Death

6-016   Special Interrogatories – Medi-Cal

6-017   Supplemental Interrogatory

6-018   Seeking Documents In A Personal Injury Case

6-019   Seeking Documents In A Wrongful Death Case

6-020   Seeking Documents In A Property Damage

6-021   Seeking Documents Pertaining To Medicare//Medi-Cal/Haniff/Howell Issues

6-022   Supplemental Request for Production of Documents

6-023   Privilege Log

6-024   HIPAA-Compliant Authorization of Medical Records

6-025   Request for Admissions

6-026   Request for Physical Examination

6-027   Stipulation for Mental Examination

6-028   Stipulation for Mental Examination Attachment

6-029   Stipulation Limiting Claim and Precluding Mental Examination

6-030   Motion for Order Regarding Mental Examination

6-031   Memorandum of Points and Authorities In Support of Order Regarding Mental Examination

6-032   Separate Statement of Undisputed Facts In Support of Order Regarding Mental Examination

6-033   Declaration In Support of Order Regarding Mental Examination

6-034   Declaration of Doctor  in Support of Order Regarding Mental Examination

6-035   Notice of Taking Deposition

6-036   Notice of Taking Deposition With Notice To Produce Documents

6-037   Notice of Taking Videotaped Deposition

6-038   Notice of Taking Deposition Out-of-State

6-039   Application for Issuance of Commission

6-040   Commission To Take Out of State Deposition

6-041   Notice of Taking Deposition of Treating Physician

6-042   Notice of Taking Deposition of Expert Witness

6-043   Stipulated Protective Order – Proprietary Documents

6-044   Stipulated Protective Order – Preservation of Evidence

6-045   Demand To Exchange Expert Witness Information

6-046   Expert Witness List and Supporting Declaration

6-047   Notice of Motion To Compel Responses To Discovery – When No Response Provided

6-048   Memorandum of Points and Authorities In Support of Motion To Compel Responses To Discovery – When No Response Provided

6-049   Proposed Order Granting Discovery Responses

6-050   Motion To Compel Responses To Discovery –When Responses Provided are Inadequate

6-051   Memorandum of Points and Authorities In Support of Motion To Compel Responses To Discovery – When Responses Provided are Inadequate

6-052   Separate Statement of Facts In Support of Motion To Compel Responses To Discovery – When Responses Provided are Inadequate

6-053   Declaration In Support of Motion To Compel Responses To Discovery – When Responses Provided are Inadequate

6-054   Separate Statement of Disputed Questions and Answers

6-055   Motion To Quash Deposition

6-056   Motion To Have Matters Deemed Admitted

6-057   Declaration In Support of Motion that Matters Deemed Admitted

6-058   Federal Court – Initial Disclosures

 

Chapter 7: Alternative Dispute Resolution Correspondence

7-000   Chapter 7 Practice Tips

7-001   Letter Advising Client/Insured of ADR Session

7-002   Letter Regarding Rejection of Proposed Arbitrator

7-003   Letter To Opposing Counsel Confirming Settlement

7-004   Letter To Client/Insured Advising of Settlement

7-005   Letter To Opposing Counsel Providing Settlement Agreement and Release

7-006   Letter To Opposing Counsel Providing Settlement Check Pleadings

7-007   Settlement Conference Statement

7-008   Mediation Position Statement

7-009   Settlement Agreement and Release, Including Provisions for Confidentiality of Settlement, Addressing Medicare Priority Rights of Recovery and Other Liens, Confidentiality of Settlement Disposition of Material Produced During Litigation

7-010   Settlement Agreement and Release, Including Provisions for Confidentiality of Settlement Claims of Minors Or Others Without Legal Capacity To Contract

7-011   Settlement Agreement and Release, Including Provisions for Confidentiality of Settlement Claims for Wrongful Death

7-012   Settlement Agreement and Related Documents for A Structured Settlement

7-013   Settlement Agreement and Mutual Release

7-014   Application for Determination of Good Faith Settlement

7-015   Notice of Application for Determination of Good Faith Settlement

7-016   Declaration In Support of Application for Determination of Good Faith Settlement

7-017   Proposed Order

7-018   Motion To Enforce Settlement

7-019   Stipulation To Submit Case To Non-Binding Arbitration and Keep Discovery Open

7-020   Stipulation To Submit Case To Binding Arbitration

7-021   Offer of Evidence At Judicial Arbitration

7-022   Request for New Trial (Trial De Novo) After Judicial Arbitration

7-023   Offer To Compromise and Acceptance Under CCP Section 998 (for Entry of Judgment and for Settlement)

7-024   Offer of Judgment Under FRCP 68

 

Chapter 8: Trial Correspondence

8-000   Chapter 8 Practice Tips

8-001   Letter Advising Insured/Client of Trial Date

8-002   Letter Advising Witnesses of Trial Date

8-003   Letter Confirming Trial Date With Expert Witnesses Pleadings

8-004   Peremptory Challenge To Judge

8-005   Stipulation and Order To Continue Trial (Convenience of Counsel)

8-006   Stipulation and Order To Continue Trial(Complex Facts)

8-007   Motion To Bifurcate Trial

8-008   Notice of Motion To Continue Trial

8-009   Memorandum of Points and Authorities In Support of Motion To Continue Trial

8-010   Declaration In Support of Motion To Continue Trial

8-011   Motions In Limine

8-012   Trial Brief

8-013   Jury Instructions

8-014   Statement of The Case

8-015   Notice and Motion To Confirm Arbitration Award

8-016   Notice of Hearing

8-017   Memorandum of Points and Authorities In Support of Motion To Confirm Arbitration Award

8-018   Declaration In Support of Motion To Confirm Arbitration Award

8-019   Jury Questionnaire

8-020   Notice To Appear At Trial

8-021   Notice To Produce Documents At Trial