Is a plaintiff entitled to the production of manuals, procedures, and guidelines that relate to the manner in which the insurer handles claims?

Micciche v. Mittag, [2001] O.J. No. 3386, is similar. The plaintiff sought the production of manuals, written policies, procedures, protocols, and guidelines that related to the manner in which the insurer administered claims. The plaintiff did not specifically plead bad faith but instead simply said that the insurer had acted in a manner that was “high-handed, arrogant, and irresponsible” and that its refusal to pay benefits should entitle her to punitive, aggravated and exemplary damages.