Centralized Subpoena Unit

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Liberty Mutual Insurance (“Liberty”) has a centralized department for processing non-party / third-party subpoenas issued under open and active litigation and served on Liberty’s domestic affiliates.  This department works under the supervision of Company attorneys to review and enforce service of process compliance, collaborate and cooperate with key internal and external stakeholders, refer to specialty departments for handling or review and respond depending on the nature of the request and the business segment involved.

Service of Process 

Liberty requires that service of process be made in full compliance with applicable law and state DOI guidelines and will not accept service of process by any means not specifically authorized.  Improperly served subpoenas will be rejected and you will be notified via correspondence which will include service of process instructions for your jurisdiction.

In many states, Corporation Service Company is Liberty’s designated Registered Agent, but we encourage you to reach out to your state’s DOI for accurate and up-to-date service of process information.  If you still have questions regarding service of process, please reach out to subpin@libertymutual.com and provide the state that has jurisdiction over the litigation under which you are issuing your request.

In addition to service of process, it is imperative that your subpoena conform to federal, state and local guidelines.  This could include, but is not limited to: complete and accurate case caption, case number, dates, signatures and notice to opposing parties.

Scope of Request Recommendations 

Vague requests or incorrect information may result in limited responses based on good faith interpretation of scope or require additional research which may delay timely production of a response.  For efficient processing, we recommend including the following in your request:

  1. Type of record requested.
  2. Line of business, if applicable.
  3. Proper underwriting company, if known.
  4. PII (in accordance with any local privacy laws) – full name, date of birth, SSN/EIN.
  5. An authorization for release of medical records (jurisdiction-specific requirement).
    • If you are seeking medical records on a minor or incapacitated individual (presently or at time of loss), Liberty requires an authorization to accompany the subpoena.
       

Invoicing & Payment 

Invoicing

Liberty reserves the right to charge reasonable copying costs and labor fees.  Unless pre-approval thresholds are specified in your cover letter, we will issue an invoice at the time we release the production response to you.  Payment is appreciated within 30 days. Unpaid invoices may be subject to collections.

Generally, invoicing is as follows:

  • Labor: $25.00/hour*
  • Electronic copies: $0.25/page*

*Charges in CA as follows: $24.00/hour and $0.10/page

Payment

Payment can be made electronically via our secure portal (preferred) or by physical check.  To ensure proper allocation, it is imperative that you include the 8 digit Liberty invoice number with your online payment or written on your physical check.

PORTAL: https://www.payconnexion.com/pconWeb/public/session/new/LIB/MUT/SinglePayment

  • Payments made with incorrect or missing invoice numbers could result in incorrect payment allocation.
  • For proper allocation, a single payment must be entered for each invoice. Bulk payments covering multiple invoices or making multiple, smaller payments against an invoice could result in incorrect payment allocation.

PHYSICAL CHECK:  For proper allocation, please include the Liberty invoice number and your work order number or case number on your check and mail to:

LM - Centralized Subpoena Unit
350 E. 96th Street,
Mailstop 2B,
Indianapolis, IN 46240


Contact Information 

Email preferred

When contacting our department for status or general inquiries, please provide your reference number (work order or case number) and plaintiff’s name.  When contacting with a billing question, please provide the Liberty invoice number.