In an ideal world, policyholders would not need to resort to litigation to recover the insurance proceeds to which they are entitled. But the reality is that insureds often have no choice but to bring a lawsuit to enforce their rights to coverage. For the vast majority of policyholders, insurance coverage litigation is a rare event. With limited exception, insured companies are not in the business of insurance, and as such, their internal policies and procedures are not developed with insurance litigation in mind. For insurers, however, insurance coverage litigation is routine. And when insurance coverage litigation reaches the discovery phase, the disparate nature of the parties' businesses (insured v. insurer) can make all the difference.