Texas court shuts down pre-suit discovery in Berkley Insurance case
In response, Naymola filed a Rule 202 petition seeking pre-suit depositions of BRIC, BNIC, Cusack, and an unnamed individual (“John Doe”) to investigate potential tort claims arising from how the settlement agreements were obtained. He argued that if the releases are ultimately deemed unenforceable, he may have viable claims against Berkley and its representatives. The petition also requested extensive document production, including claim files, communications between the insurers and the Edwards plaintiffs, communications with legal counsel and third parties, drafts of the releases, and accident-related documentation.
