Staffing, Retention of Experts and Document Management

  • Designated Trial Counsel. Counsel should designate which attorney shall serve as “trial attorney” and that person should have primary responsibility for the case development.
  • Staffing Efficiencies. The case should be staffed economically and effectively, with one partner, the “trial attorney” and one associate. The trial attorney should articulate with specificity to both The Hartford Global Specialty Financial Lines (HGS-FL) Claim Handler and each billing professional the roles and responsibilities of each billing professional and duplication of effort should be avoided. Unless pre-approved, only one time keeper will be reimbursed for attending such events like trial, depositions, appearances, and witness interviews.
  • Retention of Experts. Generally, HGS-FL encourages the early retention of consulting experts and encourages their retention prior to any settlement negotiations. Many of our policies require our prior approval of the retention of an expert.
  • Document Management. In complex cases involving hundreds, if not thousands, of documents (including electronic files), counsel should confer with and get approval from the HGS-FL Claim Handler and the insured with respect to the document (including electronic files) management system counsel seeks to employ and whether a vendor should be hired for assembling, organizing and searching such documents.
  • Depositions. Counsel should consult with the claims professional before initiating and attending depositions other than that of the plaintiff(s), the insured, and other depositions already approved in the initial litigation plan or supplement thereto.
  • Interoffice Conferencing. If inter-office communication is related to coordination of work or ordinary office communication it is not reimbursable. If interoffice communication is related to the substantive aspects of the case and it is intended to provide a more effective defense it is reimbursable but only for the most senior time keeper.
  • Multiple Attendees. Unless pre-approved, only one time keeper will be reimbursed for attending such events like trial, depositions, appearances, and witness interviews.
  • Legal Research. Counsel should consult with the claims professional before undertaking a legal research project requiring over two hours of research. Copies of all research memoranda shall be provided to Insurer upon request.
  • Motions. Counsel should consult with the claims professional before filing any motions not previously identified and approved in the initial litigation plan or supplement thereto.
  • Revising Standardized Forms / Pleadings. Only the actual time spent in personalizing standardized pleadings, documents, discovery responses or requests to the case at hand should be billed.