Sample Letter to Insurance Carrier Regarding First Party Bad Faith

Dear Adjuster [name]:

The purpose of this letter is to issue a final request for medical payments coverage before filing suit with respect to the above captioned matter.

On [date] our client, your insured, was struck from the rear with significant force by another party. A claim has since been filed against such party and your company has already filed a lien pursuant to your subrogation rights. Therefore, any payments made with respect to our client’s medical payments coverage are likely to be reimbursed to your carrier in due course.

By date of [dates], requests were made to you and your carrier that medical payments with respect to the bills listed below be provided to the medical personnel who assisted our client. As of this date, no bills have been paid nor has my client received any compensation regarding his medical payments coverage. You have had more than ample opportunity to investigate the facts of this case, including the police report and the medical reports which have been furnished to you.

We hereby request that the following bills be paid immediately:

[list unpaid bills, as for example:

. Dr. John Jones - $326 for services performed on 8/18, 9/22, 10/1, and 11/3/99.

. Pop Physical Therapy in the amount of $468 for physical therapy treatments between October 1, and November 16, 1999.

. Mid State Hospital in the amount of $227 for x-rays on September 23, 1999 and emergency treatment on 8/16/99.

. Dr. Sam Smith, Neurosurgeon, in the amount of $420 for a consultation of November 2, 1999.

. Mid State Imaging for an MRI in the amount of $890 conducted on November 6, 1999.]

Despite many requests that these bills be honored, you have refused and continue to refuse to honor these bills. Our client has received collection letters from at least two of these facilities and we anticipate that his credit rating will be affected by your failure to pay bills.

Please be reminded that [relevant state code section] provides for...