Coercive Letter to Insurance Company Regarding Payment of Policy Limits

Ajax Insurance Company

Address

City, State, Zip

Dear Ajax Insurance Company:

My client rejects your offer of $80,000.00.

As I have previously indicated, we will not accept anything less than the $100,000.00 liability policy limit. No structured settlement will be considered unless the cash value equals $100,000.00. Given the amount of the medical bills, the existence of future impairment, the necessity of future surgery and the substantial punitive damages claim, the value of this case is in excess of $200,000.00. Nevertheless, my client has been willing to release your insured in exchange for payment of the $100,000.00 liability policy limits.

Ajax Insurance Company has a duty to exercise "good faith" in attempting to settle this claim within your insured's policy limits. If it is necessary for us to file suit, and if we obtain a verdict in excess of the policy limits, I believe your insured would have a "bad faith" claim against Ajax Insurance Company for compensatory and punitive damages because the damages are clearly in excess of the policy limits. If such claim is successful, Ajax Insurance Company would be responsible for any amount which your insured is required to pay in excess of the policy limits plus punitive damages.

We have sent you medical bills totalling $30,000.00. In addition, Dr. Smith's letter of...