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... fee recovery has been granted as part of an insurer's obligation to defend the policyholder. • Sherwood Brands, Inc. v. Hartford Accident & Indemnity Co., 347 Md. 32 ... of great importance to the client. C. Right to Independent Counsel Right Not Created Johnson v. Continental Cas. Co., 788 P.2d 598, 363 (Wa. App. ... related items. Policyholder counsel should request that the insurance company set forth the basis for audit counsel's investigation and review, including the assumptions upon which " ...