Court rulings over the past decade in insurer/policyholder disputes have established that liability policies dating back to the 1960s and earlier can provide millions of dollars in coverage to policyholders with environmental liabilities. Many policyholders, however, are unable to locate their old policies and find that their insurers and brokers cannot either. Policyholders who have destroyed or lost their policies will need to reconstruct their coverage from secondary evidence. If they wind up in court, the policyholders have the burden of proof and must show that (1) they conducted a diligent search for the policies but could not locate them; (2) the policies did, in fact, exist; and (3) the key coverage terms in the lost policies are, in fact, as claimed by the policyholders. A survey of reported cases reveals that courts have differed widely over the nature and extent of secondary evidence sufficient to prove the existence of a lost policy. The reported cases underscore the importance of convincing the reviewing court to apply the “preponderance of the evidence” standard of proof on this issue, rather than the “clear and convincing” standard. Regarding policy exclusions, courts have uniformly held that once a policyholder proves the existence of the policy and the key terms of coverage, the insurer then has the burden of proving the existence and wording of exclusions in the policy.