The court concluded that the trial court had abused its discretion by ordering the deposition of a corporate representative for the auto insurer in a lawsuit regarding UM/UIM coverage because the insurer had already produced its entire non-privileged claims file and the information sought from the corporate representative was included in the claims file and therefore, the addition of testimony from a corporate representative, who did not have personal knowledge of the claim, would provide little, if any, additional benefit, and therefore was not proportionate to the needs of the case.
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