Trial Stipulation of Uninsured Motorist Case

In the Circuit Court for Prince George’s County, Maryland
Civil Division




Case No.: CAL10-03062

Stipulations Between the Parties

The parties, Plaintiff Randy Maxfield, (hereinafter Plaintiff Maxfield) Defendant Candice Fioravanti, (hereinafter Defendant Fioravanti) and Defendant Brethren Mutual Insurance Company (Defendant Brethren) have reached the following stipulations in this above captioned case and agree as follows:

  1. Plaintiff Maxfield was insured under an automobile insurance policy issued in the State of Maryland by Defendant Brethren for a motor vehicle that was registered in the State of Maryland and being operated by Plaintiff Maxfield on November 21, 2013, which was involved in a collision with a vehicle being operated by Defendant Fioravanti.
  2. Defendant Brethern’s policy is identified as policy number CPP0011834 and was in full force and effect on November 21, 2013, with limits of up to $1,000,000.00 for coverage in claims of uninsured or underinsured motorists benefits.
  3. Pursuant to §19-509 of the Insurance Article of the Annotated Code of Maryland, the Brethren policy provided monetary benefits to Plaintiff Maxfield in the event that he was injured in an automobile collision by the operator of another motor vehicle that did not carry adequate liability insurance at the time of the collision and whose vehicle was underinsured, to specifically include any such damages that the Plaintiff may have sustained in the automobile collision that occurred on November 21, 2013, which is the subject matter of the above referenced case
  4. Defendant Candice Fioravanti was insured with GEICO insurance company on November 21, 2013 and her liability limits are in the amount of $300,000.00. This is the only liability policy applicable to the losses sustained by the Plaintiff in the automobile collision of November 21, 2013. Plaintiff Randy Maxfield contends that his damages exceed the available limits of Defendant’s Fioriavanti’s lability policy.
  5. Plaintiff Maxfield is not in breach of any of the contractual provisions contained in the insurance policy issued by Defendant Brethren, has complied with all conditions precedent to bringing a claim for uninsured/underinsured benefits under the policy, has made a claim for monetary benefits under the policy; and to date, Defendant Brethren has not made any payments to the Plaintiff Maxfield under the uninsured/underinsured provisions of the policy.
  6. All parties agree that the coverage limits are not admissible at the trial of this matter and shall not be put into evidence before the Jury.
  7. In the event that the jury awards Plaintiff Maxfield any damages in this case, judgment would be entered against Defendant Fioravanti for the full amount of the judgment; and judgment would be entered against Brethren in the verdict amount above $300,000.00 up to the policy limits of $1,000,000.00. Brethren’s total exposure in this case is $700,000.00.
  8. In the event that the jury awards Plaintiff Maxfield damages in the amount of $300,000.00 or less, then judgment would be entered against Defendant Fioravanti only.
  9. Theses stipulations to not impact any parties’ rights to appeal the verdict in this case and all rights to appeal by all parties are reserved. The parties’ intentions in entering into the stipulations are to streamline the trial of this matter on evidentiary issues.

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