Sample Bad Faith Letter in Car / Truck Accident Case

Steven C. Johnson, Esquire
Johnson & Daniels
4601 Main Street, Suite 225
Bowie, Maryland 20715

Re: Hancock v. Minotz, et al.
Case No. CAL06-02794; Circuit Court for Prince George’s County, Maryland
Dear Mr. Johnson:

Please accept this correspondence as Plaintiff’s formal written demand for your client’s available policy limits in this case. It is my understanding that your client has $300,000 in coverage available for this loss. Taking into consideration the clear negligence established by your insured’s left hand turn in front of our client and given the extent of our client’s amputation of his leg, it is our position that a verdict against your client would be greatly in excess of your client’s available policy limits.

We expect you to offer the full $300,000 policy limit in order to protect your client’s best interests and insulate him from an excess judgment. Our client will accept the $300,000 as full and final settlement of all claims.

Please be advised that we intend to present evidence and arguments at trial to the Jury that this case is clearly worth a significant amount of money and will be asking the Jury to award an amount in excess of your client’s available policy limits. As such, please put your client on notice that because the claim is in excess of his available policy limits, any personal attachable assets he may have would be at risk, and his wages would be at risk of being garnished when an excess verdict is entered against him.

I trust that you will promptly convey this demand to your client and the representatives of his insurer. I would assume that you join us in this position, since it is your duty to protect your client and his best interests. If you have not already done so, please notify GEICO that we believe their failure to offer the available policy limits in order to protect their insured is operating in bad faith. GEICO’s failure to offer limits in this case would be demonstrative of a greater concern for their own monetary interests than the financial hardship and devastation to their insured.

Your client should be advised to retain separate counsel to represent his interests in this matter. I have enclosed three additional copies of this correspondence (one for GEICO, one for your client and one for the attorney your client has retained to represent him for his excess exposure).

Please let me know GEICO’s response to this settlement demand within the next 30 days. I look forward to hearing back form you.

Very truly yours,
Laura G. Zois

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