§ 12:1 Suggested motion text

“[Name of moving party/insured] hereby moves this Court for an order instructing defendant [name of insurer] and its counsel not to refer to, interrogate concerning, comment on or attempt to suggest to the jury that the denial of insurance coverage under the terms of defendant [name of insurer]'s insurance policy was based on any other information except what was in the claim file at the time of denial. The motion is based upon the grounds that this evidence would be irrelevant to the issues in this case and that an insurer has a statutory duty to investigate a claim before issuing its denial.”

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