By Andrew Noll and Matthew Jacobs, Jenner and Block LLP (May 5, 2017, 1:06 PM EDT) -- Insurance coverage disputes are about the interpretation and application of policy wording. One of the richest sources of information regarding the insurer's construction of its own policy language is the underwriting file. That is where underwriters often reflect their understanding of how a proposed endorsement to coverage will enhance (or restrict) coverage. Moreover, underwriters often explain why they have proposed specific policy wording to meet the insured's business needs, and how a provision would apply should a claim arise. The information is highly relevant, and therefore discoverable. If insurers raise concerns about the production of proprietary business information, or even potentially privileged communications, courts are well-equipped to take any necessary steps to protect such information while still permitting the discovery of relevant information from the insurer's underwriting file....