in Re Allstate Vehicle and Property Insurance Company, 09-22-00023-CV

Allstate sought mandamus relief to vacate a January 13, 2022 trial-court order compelling production of the so-called “McKinsey Slides” and “Homeowner CCPR” documents previously produced in a federal case (Tarver v. Allstate) under a protective order.
The requested production encompasses approximately 13,455 pages of materials prepared from about 1992–2000 concerning Allstate’s Claims Core Process Redesign (CCPR).
Dumas (real party in interest) alleges Allstate’s historic CCPR concepts were absorbed into its ongoing claims culture and contributed to deceptive practices and bad-faith handling of her 2018 water-damage claim.
Allstate argued the requests are facially overbroad, seek decades-old, irrelevant information, and are disproportionate and unduly burdensome relative to Dumas’s 2018 claim.
The court held the trial court abused its discretion by compelling production in response to overbroad discovery requests and conditionally granted mandamus vacating the production order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether production of the McKinsey/CCPR materials was discoverable	The CCPR concepts persist in Allstate’s claim culture and are relevant to Dumas’s bad-faith and deceptive-practices claims	The materials are 20–30 years old, unrelated to the 2018 claim, overbroad and not proportional	Trial court abused discretion; compelled production was overbroad and must be vacated
Whether mandamus is appropriate (adequacy of appellate remedy)	Implicitly contends appeal could suffice	Allstate: no adequate remedy by appeal for compelled overbroad discovery	Court found Allstate lacks adequate remedy by appeal and granted conditional mandamus
Whether discovery requests were reasonably tailored in time/scope	Dumas conceded age but contends substance persists, justifying broad production	Requests could and should have been narrowly tailored to materials effective when claim arose	Requests were facially overbroad; discovery must be limited by relevant time/scope
Whether court should consider other evidentiary rulings (e.g., striking declaration)	Dumas relied on trial-court rulings supporting discovery	Allstate challenged striking of Don Odom declaration among other rulings	Court did not address remaining issues and granted mandamus based on overbreadth alone

In re Colonial Pipeline Co., 968 S.W.2d 938 (Tex. 1998) (mandamus standard for correcting discovery orders)
In re CSX Corp., 124 S.W.3d 149 (Tex. 2003) (overbroad discovery and tailoring requirement)
In re National Lloyds Ins. Co., 449 S.W.3d 486 (Tex. 2014) (limits on overbroad discovery)
In re National Lloyds Ins. Co., 507 S.W.3d 219 (Tex. 2016) (discovery not permitted for matters unrelated to event at issue)
In re Allstate County Mut. Ins. Co., 227 S.W.3d 667 (Tex. 2007) (overbroad requests improper regardless of burden)
In re K & L Auto Crushers, LLC, 627 S.W.3d 239 (Tex. 2021) (overbreadth defined by time, place, subject matter)
Texaco, Inc. v. Sanderson, 898 S.W.2d 813 (Tex. 1995) (discovery must be reasonably tailored)
K Mart Corp. v. Sanderson, 937 S.W.2d 429 (Tex. 1996) (disallowed discovery used as a fishing expedition)