AAJ Exchange Litigation Packet Catalog - American Association for ...

UnumProvident Bad Faith: Occupational
Stress Deposition Collection
[UPDATED November 2005; 1,044 pages]
• Own occupation policy
• Step-by-step analysis of how
UnumProvident handled the claim
• Insurer engaged in questionable
communications with DME who later
altered evaluation Report
• Testimony from the DME and company
claims, vocational, and medical personnel
• Information on October 2005 class
action filing
[Deposition summary accompanies
each deposition transcript]
UnumProvident Corporation Customer
Care Center Claims Manual (April 2001)
[April 2001; 542 pages]
• Long term, short term, and individual disability
• Long term care insurance
• Life insurance
• State law governing claims handling
UnumProvident Corporation Customer Care
Center Claims Manual (November 2002)
[November 2002; 644 pages]
• Expanded version of the April 2001 edition
• Long term, short term, and individual disability
• Long term care insurance
• Life insurance
• State law governing claims handling
Workers’ Compensation Bad Faith:
AIG and American Home Assurance
Incentive Programs
[July 2006; 740 pages]
• Profiles a bad faith workers’ compensation
claim where the carrier and its third party
administrator denied benefits based on an issue
of new accident versus need for further medical
treatment in relation to a prior accident
• Substantial verdict against AIG
• AIG found fully responsible for breach of its
duty and liable for life-time medical care and
disability benefits
• Plaintiff produced evidence that defendants
received financial incentives to cut claim
costs rather than focus on fair evaluation of
compensable claims
• Contains key court documents including:
Plaintiff’s Initial Disclosure Statement,
Plaintiff’s Requests for Production of
Documents, Plaintiff’s Statement of Facts,
Plaintiff’s Motions to Compel for Production
of Documents, Plaintiff’s Motion for Partial
Summary Judgment on Issues of Bad Faith,
Plaintiff’s Reply Briefs on Motions to
Compel and for Sanctions, and more
• Deposition transcripts and summaries
from AIG employees involved in all aspects
of claims handling
• Deposition transcripts and summaries from
the Plaintiff Insurance Expert and a trial
transcript and summary from the Plaintiff
Orthopedic Surgeon
[Deposition summary accompanies
each deposition transcript]
Motor Vehicle/
Automobile Products Liability
Automobile Data Recorder:
Litigating the “Black Box” Issue
[UPDATED March 2006; 685 pages]
• Technical explanation about how
the black box works
• Strategies on preservation and downloading
of data, use of experts, ownership of data,
and other issues
• Discovery requests, trial transcripts, and
other filings in prominent cases
• Verdicts and settlements
Crashworthiness Cases
[UPDATED September 2006; 1,394 pages]
• Court documents from three cases, each
of which addresses one element of
crashworthiness: rollover crashworthiness,
door latch defects and frontal crashworthiness
• Federal Motor Vehicle Safety Standards
and Regulations
• NHTSA crash data materials and a list
of pertinent Internet resources
• Department of Transportation Notice
of Proposed Rulemaking regarding roof
crush resistance
[Deposition summary accompanies
each deposition transcript]
Firestone Tire Tread Separation
[August 2000; 929 pages]
• August 2000; ATX, ATXII, and
Wilderness AT tire recalls
• Pleadings and other court documents
from across the country
• NHTSA documents
Interstate Trucking: Independent
Contractor Defense
[March 2007; 340 pages]
• Discussion and guidance regarding how
to overcome the independent contractor
defense: statutory employee doctrine
and nondelegable duty
• Addresses how to use discovery and
jury instructions to establish and
strengthen liability
• Sample plaintiff motion for partial summary
judgment and trial brief
• Internet resources: federal government,
safety advocacy and research, and
industry resources
Interstate Trucking Regulations,
Discovery and Damages
[UPDATED December 2006; 1,529 pages]
• Discussion and guidance regarding the
hours-of-service-of-drivers, cargo securement,
and alcohol and drug regulations
• Sample complaints and discovery requests
• Deposition of an expert on collision
warning systems
5 www.justice.org/exchange | 800-344-3023 | 202-965-3500, ext. 615