In Agilis Benefit Services, LLC v. Travelers Cas. and Sur. Co., NO. 5:08-CV-213, 30-31 (E.D. Tex. Feb. 24, 2010), the insurance policy at issue, like the subject policy here, defined a "claim" in part as "a written demand for monetary or non-monetary relief" and did not contain a definition of the term "relief." See, id.
The court found that the term "relief" was broad enough to include a demand for "something due" and held that the documents plaintiffs were commanded to produce pursuant to a grand jury subpoena were written demands for non-monetary relief. See, id.