Insurance Defense OCR: Working an Assigned Defense File

In insurance defense, OCR earns its keep on the day a carrier assigns a file. The package arrives as scans: the complaint, the policy, the adjuster's file and whatever records the claimant sent. Convert those to searchable text, sorted by where each came from, and you can answer the suit and report to the carrier from the documents themselves.

The work below follows one assignment from arrival to the first report. The matter is invented: Harlan Mutual assigns the defense of its insured, Delgado Roofing, after a homeowner named Priya Raman sues over a fall from a ladder left on her driveway.

The assignment scan usually holds the complaint and the policy together. Search the policy for the liability insurance grant and for occurrence policy wording, then search the letter for a reservation of rights. That complaint is the third-party claim the insurer tendered for the insured, which is where a duty to defend review starts. Confirm the named insured and the limits on the image before the first report.

What arrives when a carrier assigns a defense file?

A carrier's assignment arrives as a handful of large PDF attachments: an assignment letter, the suit papers, the policy, the claim file to date and any records the claimant supplied before suit. Expect image-only pages wherever a document was printed, faxed or exported from a claim system as pictures of pages.

The pieces differ a great deal in how they were made, which decides how each one converts.

Two things follow from that table. First, a package that looks like five attachments is really forty or fifty documents, and none of them is marked off from the next. Second, the pieces come from three different sources with three different standings in the case: the carrier, the claimant and the insured. Keep that in mind from the first hour, because it shapes how the folder is built.

The adjuster's file is the largest attachment and the one with the most unfamiliar layouts. The post on OCR for claim files describes what is inside an insurance claim file section by section, so this post treats it as one block and concentrates on the rest of the package.

Which insurance defense documents repay conversion first?

Convert first the insurance defense documents that carry a deadline or a figure: the complaint, the declarations page and endorsements, the pre-suit demand, and the claim notes. Those four answer the questions the carrier asks in week one. Photographs, duplicate letters and fax cover sheets can wait, and some never need converting.

A useful way to rank the pile is to ask what you will do with the text.

1. The summons and complaint. You will quote its paragraphs when you draft the answer, and you need the service date and the court. Convert it to Word so the allegations can be pasted into an answer shell and numbered to match. Read every paragraph number against the page.
2. The declarations page and endorsements. You need limits, the policy period, the named insured and any endorsement that changes who or what is covered. These pages are short and dense, and they are where a wrong digit hurts most.
3. The pre-suit demand letter. It states the claimant's theory, the injuries claimed and a number. Converted, it gives you a checklist of every provider and every bill the plaintiff relies on.
4. The claim notes and the adjuster's correspondence. They tell you what the carrier already knows, who has been interviewed and what was said to the claimant before counsel was involved.
5. The claimant's medical records and bills. They are long, so they come after the short, urgent pieces. The method for converting medical records for attorneys covers splitting a set by provider and building a chronology, and it applies unchanged to records a plaintiff attaches to a demand.
6. The insured's contracts and incident reports. Convert them once the insured has confirmed the set is complete, since clients tend to send papers in several rounds.

What can stay as an image

Some pages gain nothing from recognition. A photograph of a ladder has no text to find. A fax cover sheet repeats what the letter behind it says. Twelve copies of the same reservation of rights letter, each forwarded with a new email header, need one conversion. Note these in your index as "image, not converted" so nobody later wonders whether a page was skipped by mistake.

Converting an assignment package on the day it lands

Convert an assignment package in one sitting: save the attachments untouched, split working copies into one file per document, name each by source, upload them, and check the short urgent documents before anything else. Done in that order, the complaint and the coverage pages are searchable within the first hour.

A sequence that works for a package of a few hundred pages:

1. Save what the carrier sent, exactly as sent. Put the original attachments in a folder named for the date received and do not open them for editing again. Every later question about what the carrier provided is answered from this folder.
2. Read the assignment letter before anything else. It names the adjuster, the claim number, the insured and the reporting dates the carrier expects. Reporting requirements differ from carrier to carrier, so take them from the letter and the guidelines attached to it, never from habit.
3. Split the large attachments at document boundaries. Page through each PDF and mark where a new document starts: a new letterhead, a new form number in the footer, a new caption. Cut copies there. A 300-page claim export might become 35 working files.
4. Name each file by source, date and type. For example CARRIER_2026-03-04_reservation-of-rights.pdf, PLTF_2026-01-18_demand-letter.pdf, INSURED_2025-11-02_roofing-contract.jpg. The prefix does the sorting for you later.
5. Upload in priority order. Send the complaint, the declarations page and the demand letter first. Schema Law takes PDF, PNG or JPEG files up to 20 MB, and the three steps on the homepage are the whole procedure: upload, wait for the pages to be read, export.
6. Check the urgent documents against their images. Read the service date, the court, the claim number, the policy number, the limits and the demand figure character by character.
7. Export by purpose. Word for the complaint, searchable PDF for everything you will file to the matter, Excel for any page that is mostly a table, such as a repair estimate or a billing summary. The list of export formats shows what is available.
8. Write the index as you go. One row per working file, described in the section on keeping sources apart.

Volume and plan limits

An assignment package is small next to a discovery production, but a defense practice receives many of them. If your office takes ten assignments a month at 400 pages each, that is 4,000 pages before any discovery arrives. The Solo plan covers 1,000 pages a month and up to 250 pages per document. The Team plan covers 10,000 pages a month, and up to 1,000 pages per document. On either plan you can choose several files at once, so a split package goes up in one pass and is read one file after another. The pricing page has the full comparison.

Whether the cost of conversion can be charged to the file is a question for the carrier's billing guidelines and your engagement terms, and they vary widely. The post on OCR cost per page explains the arithmetic of passing OCR costs through to a matter for firms that are permitted to do so.

Policy forms, endorsements and declarations pages as scans

A scanned policy converts well in its long printed forms and needs care on the declarations page and the endorsement schedules, where the facts specific to this insured sit in small boxes. Convert the whole policy to a searchable PDF, then proofread the declarations and every endorsement that carries a typed-in name, date or amount.

A policy is assembled from parts, and each part behaves differently under recognition.

• Declarations page. A grid of labeled boxes: named insured, mailing address, policy number, policy period, limits, deductibles, premium, and a schedule of forms. Recognition may read the boxes in an order that separates a label from its value. Read the page image beside the text and correct the pairing by hand.
• Coverage forms. Many pages of printed text in two columns with numbered and lettered sections. These usually convert cleanly, and they are the pages you will search most. Check that the columns were read down and not across by reading one full section in the output.
• Endorsements. Each has a form number and edition date in a corner or footer, a title, and often a schedule with typed entries such as an additional insured's name or a described location. The printed part is easy. The typed schedule is where the case-specific fact lives.
• Certification page. A certified copy carries a stamp or signed statement from the carrier. Treat the stamp and signature as marks on the image, not as text.

Reconciling the forms schedule

The declarations page normally lists every form and endorsement that makes up the policy, by form number and edition date. That list is a ready-made completeness check.

1. Copy the forms schedule from the converted declarations page into a spreadsheet, one form number per row.
2. Search the converted policy for each form number and record the page where that form begins.
3. Mark any listed form you cannot find, and any form in the scan that the schedule does not list.
4. Send the gaps to the adjuster with a request for the missing pages.

In the Delgado Roofing file, the schedule lists eleven forms and the scan holds ten. The missing one is an endorsement whose title suggests it limits coverage for work above a stated height. That is worth knowing before anyone tells the carrier how the policy reads.

The policy also matters outside the coverage analysis. In federal court, the initial disclosures required by Federal Rule of Civil Procedure 26(a)(1)(A)(iv) include, for inspection and copying, any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment. State courts have their own disclosure rules, so check the one you are in. A clean, complete, searchable copy of the policy saves you from assembling it twice.

One caution on roles. Defense counsel assigned to represent the insured and coverage counsel advising the carrier do different jobs, and what assigned counsel may do with coverage information depends on the rules of professional conduct in your jurisdiction. This post covers handling the pages. It does not address that question.

How do you keep the plaintiff's records apart from the carrier's file?

Keep the plaintiff's records apart from the carrier's file by sorting every working document into a folder named for its source before you convert it, and by carrying that source into the file name and the index. Source decides how a document may be used, who may see it and how you describe it later.

Three folders are enough for most assignments, with a fourth for what your own office creates.

The reason for the discipline shows up months later. A claimant's medical record often appears in the file three times: attached to the demand, copied into the adjuster's file, and produced formally in discovery. Converted text looks the same whichever copy it came from. If a quotation in a motion is traced to a page in the adjuster's file when it should cite the Bates-numbered production, someone has to redo the citation under time pressure.

An index row for every document

Keep one spreadsheet for the matter with these columns.

The "Duplicate of" column is the one that pays for itself. It tells you that the six pages at 212 to 217 of the carrier's export need no second conversion and no second read.

A Schema Law account belongs to one person, and documents stay inside the account that uploaded them, so colleagues on the assignment work from the exported files. The source folders on your own system keep the assignment together and do the work of separating whose document is whose.

Writing the initial case report from converted records

Converted records let you write the initial case report from the documents instead of from memory: search finds each fact, you paste the passage, and you cite the page it came from. The analysis is still yours. The text only makes the supporting facts quick to locate and hard to misquote.

Use the format the carrier asks for. Many reports cover similar ground, and each part draws on a different converted file.

A drafting routine that keeps the report honest:

1. Start from the complaint. List each allegation that will need a factual response and note beside it which converted file should hold the answer.
2. Search across the source folders. In the example, searching the claim notes for "ladder" finds an early entry recording that Delgado's foreman said the crew had left for lunch. Searching the insured's folder finds the job log for that day.
3. Quote, then cite. Paste the sentence into the draft with its source and page, such as "Claim notes, carrier export p. 14". Open the page image and read the quotation against it before you move on.
4. Flag conflicts. Where the demand letter and the claim notes give different dates for the fall, set both out with their pages. The carrier wants to know about the conflict, not have it resolved by guesswork.
5. List what is missing. The forms schedule check, the provider list from the demand and the witness names in the notes each produce a list of documents you do not yet have. Put those requests in the report.

A report built this way has a second use. Each cited fact is already tied to a page, so the same notes become the first draft of your discovery responses and your deposition outlines.

Before any of this, settle whether the package may go to an online service at all. The carrier's guidelines, your firm's policy and any confidentiality terms govern that. Schema Law states how uploaded documents are treated on every plan: they are never used to train an AI model, they stay inside your own account, they are encrypted in transit and at rest, and you can delete any document at any time. Compare those, as written, with what the carrier requires of its panel counsel.