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Insurance
11 min read
Areas of Expertise :
Insurance, Bad Faith, General Liability Insurance, Medical
Published Date:
Last Modified Date:
Jurisdiction:
Federal. Eleventh Circuit
Court:
A fatal September 2011 auto accident in Miami-Dade County led to years of litigation over Allstate Fire and Casualty Insurance Company's handling of claims against its insured, Michelle Soto. Soto lost control of her vehicle and crashed into a bus-stop bench where Giraldo Lopez and his wife, Magaly Nunez-Delgado, were waiting. Giraldo Lopez was struck and killed. Nunez-Delgado witnessed the collision from a few feet away and later reported physical and psychological symptoms. Soto's Allstate policy provided $25,000 in bodily injury liability coverage per person, $50,000 per accident, up to $10,000 in personal injury protection benefits per person, and a $5,000 PIP death benefit.
The plaintiffs maintained that the claims could have been resolved for $65,000 in available policy benefits, together with information concerning Soto's assets. No global settlement was completed during the 2011 negotiations. Soto later entered into a $1.5 million consent judgment consisting of $1.15 million for Giraldo Lopez's Estate and $350,000 for Nunez-Delgado, and Nunez-Delgado received an assignment of Soto's rights against Allstate. A federal jury later ruled for Allstate on the Estate's third-party bad-faith claim but found for Nunez-Delgado on her separate claim. She received $315,000 in damages and $40,486.59 in prejudgment interest, and the Eleventh Circuit affirmed the judgment in 2018.
Michelle Soto lost control of her vehicle and crashed into a bus-stop bench where Giraldo Lopez and Magaly Nunez-Delgado were waiting. The vehicle struck Giraldo Lopez, who died at the scene. Nunez-Delgado was a few feet away and witnessed the collision. Soto was insured under an Allstate automobile policy containing bodily injury liability and PIP coverage.
Soto reported the accident to Allstate on September 7, and the insurer began evaluating the claim. By that afternoon, Allstate had concluded that Soto was liable and that the fatality claim likely exceeded the policy's $25,000 per-person bodily injury limit. On September 8, Allstate advised Soto that the damages could exceed her liability coverage and leave her responsible for amounts above the policy limits. The insurer also stated that it would attempt to resolve the claims within the available insurance coverage.
On September 9, Allstate tendered the $5,000 death benefit associated with Giraldo Lopez's death. On September 12, it tendered the Estate's $25,000 bodily injury liability limit in exchange for a general release. During communications with the Lopez family's attorney, Allstate was also told that Nunez-Delgado was reporting physical and psychological symptoms after witnessing her husband's death. Her reported condition became part of the insurer's evaluation of claims resulting from the accident.
The family's attorney informed Allstate in writing that Nunez-Delgado was experiencing insomnia, headaches, high blood pressure, neck pain, depression, and other reported symptoms. Allstate requested a marriage certificate and medical records concerning her treatment. Settlement discussions continued while the insurer evaluated her claim. At that point, Allstate had not received medical bills documenting her claimed injuries.
A lawsuit was filed against Soto after the initial settlement efforts did not resolve the claims. The action included a wrongful death claim based on Giraldo Lopez's death and a negligent infliction of emotional distress claim brought by Nunez-Delgado. Allstate continued handling the claims under Soto's automobile policy while the lawsuit proceeded. Nunez-Delgado's medical condition and available coverage remained part of the claims process.
On September 29, Allstate notified its PIP department about Nunez-Delgado's claim, and a PIP file was opened. The following day, Allstate offered the full $50,000 bodily injury liability limit available for the accident. The proposal allocated $25,000 to Giraldo Lopez's Estate and $25,000 to Nunez-Delgado. It did not include the additional $10,000 in PIP benefits associated with Nunez-Delgado.
Soto was deposed on October 18 and answered questions about her personal assets. The Lopez family had authorized its attorney to resolve the claims for $65,000 in available policy benefits and also sought information showing whether Soto had collectible assets. The family had not authorized a resolution limited to the bodily injury liability limits. By October 24, Frank Lopez ended efforts to settle the claims with Allstate for the proposed combined amount, and the underlying liability litigation continued.
Soto and the claimants entered into a global settlement agreement on July 9, 2013. The agreement resolved the underlying liability claims through an agreed judgment against Soto. Nunez-Delgado also received an assignment of Soto's rights against Allstate. That assignment allowed her to pursue claims based on Allstate's handling of the underlying settlement process.
An amended consent final judgment awarded $1.15 million to Frank Lopez as personal representative of Giraldo Lopez's Estate and $350,000 to Nunez-Delgado. The combined judgment against Soto totaled $1.5 million. Her bodily injury liability coverage under the Allstate policy was limited to $50,000 per accident. The remainder of the consent judgment exceeded the available bodily injury liability coverage.
On October 15, Allstate paid $25,000 to the Estate and $25,000 to Nunez-Delgado under the bodily injury liability coverage. On October 29, it paid Nunez-Delgado an additional $10,000 in PIP benefits. Together with the $5,000 death benefit tendered in September 2011, the payments totaled $65,000. These payments were made after the earlier settlement discussions involving the same total amount had ended.
Frank Lopez, as personal representative of Giraldo Lopez's Estate, and Nunez-Delgado, individually and as Soto's assignee, sued Allstate in the U.S. District Court for the Southern District of Florida. They alleged that Allstate failed to settle the accident claims in a manner that protected Soto from an excess judgment. The claims proceeded under Florida common-law third-party insurance bad-faith principles. The litigation examined Allstate's investigation, communications, settlement negotiations, and handling of the available policy benefits.
Allstate sought summary judgment and argued, in part, that its failure to include Nunez-Delgado's $10,000 PIP benefits in an earlier settlement could not support bad-faith liability because those benefits had not yet become payable under Florida's PIP requirements. U.S. District Judge Marcia G. Cooke denied the motion. The court concluded that a reasonable jury could find, under the totality of the circumstances, that Allstate should have used the available benefits to obtain a settlement protecting Soto from excess exposure. The ruling allowed the bad-faith claims to proceed to trial without deciding whether Allstate had actually acted in bad faith.
Before trial, the district court considered several challenges to proposed expert testimony. The court limited portions of testimony from Rolando Diaz, M.D., Nunez-Delgado's treating physician, while allowing testimony concerning her condition during the period covered by the settlement negotiations. It also permitted plaintiffs' insurance claims-handling expert Donald Dinsmore to offer opinions concerning insurance practices while excluding opinions about applicable law and certain subjective characterizations of the parties' conduct. Allstate's proposed expert D. James Kadyk was excluded after the court found that he was not qualified to offer the proposed claims-handling opinions, had not demonstrated a reliable methodology for those opinions, and would not provide testimony that would assist the jury.
Following a seven-day jury trial, the Estate's claim and Nunez-Delgado's claim were considered separately. The jury unanimously found that Allstate did not act in bad faith in failing to settle the Estate's claim. It reached a different result for Nunez-Delgado and found that Allstate did act in bad faith in failing to settle her claim. Judgment was therefore entered for Allstate on the Estate's claim and for Nunez-Delgado on her individual bad-faith claim.
The district court entered an amended judgment awarding Nunez-Delgado $315,000 in damages. She also received $40,486.59 in prejudgment interest. Allstate challenged the judgment, while the plaintiffs filed a cross-appeal addressing other trial court rulings. The litigation then proceeded to the U.S. Court of Appeals for the Eleventh Circuit.
The Eleventh Circuit reviewed challenges involving the verdict structure, jury instructions, damages, prejudgment interest, and other district court rulings. In Lopez v. Allstate Fire & Casualty Insurance Co., 710 F. App'x 861 (11th Cir. 2018), the court found no reversible error. It affirmed the district court's final judgment, amended final judgment, and post-trial order. The verdict for Allstate on the Estate's claim and the judgment for Nunez-Delgado remained in place.
United States District Court for the Southern District of Florida
Case Name:
Lopez v. Allstate Fire and Casualty Insurance Company
Auto Liability Insurance
Insurance Claims
Insurance Coverage
Liability Insurance
Liability Claims
Third Party Liability
Automobile Accidents
Claims Adjuster
Damages Calculations
A fatal September 2011 auto accident in Miami-Dade County led to years of litigation over Allstate Fire and Casualty Insurance Company's handling of claims against its insured, Michelle Soto. Soto lost control of her vehicle and crashed into a bus-stop bench where Giraldo Lopez and his wife, Magaly Nunez-Delgado, were waiting. Giraldo Lopez was struck and killed. Nunez-Delgado witnessed the collision from a few feet away and later reported physical and psychological symptoms. Soto's Allstate policy provided $25,000 in bodily injury liability coverage per person, $50,000 per accident, up to $10,000 in personal injury protection benefits per person, and a $5,000 PIP death benefit.
The plaintiffs maintained that the claims could have been resolved for $65,000 in available policy benefits, together with information concerning Soto's assets. No global settlement was completed during the 2011 negotiations. Soto later entered into a $1.5 million consent judgment consisting of $1.15 million for Giraldo Lopez's Estate and $350,000 for Nunez-Delgado, and Nunez-Delgado received an assignment of Soto's rights against Allstate. A federal jury later ruled for Allstate on the Estate's third-party bad-faith claim but found for Nunez-Delgado on her separate claim. She received $315,000 in damages and $40,486.59 in prejudgment interest, and the Eleventh Circuit affirmed the judgment in 2018.
Michelle Soto lost control of her vehicle and crashed into a bus-stop bench where Giraldo Lopez and Magaly Nunez-Delgado were waiting. The vehicle struck Giraldo Lopez, who died at the scene. Nunez-Delgado was a few feet away and witnessed the collision. Soto was insured under an Allstate automobile policy containing bodily injury liability and PIP coverage.
Soto reported the accident to Allstate on September 7, and the insurer began evaluating the claim. By that afternoon, Allstate had concluded that Soto was liable and that the fatality claim likely exceeded the policy's $25,000 per-person bodily injury limit. On September 8, Allstate advised Soto that the damages could exceed her liability coverage and leave her responsible for amounts above the policy limits. The insurer also stated that it would attempt to resolve the claims within the available insurance coverage.
On September 9, Allstate tendered the $5,000 death benefit associated with Giraldo Lopez's death. On September 12, it tendered the Estate's $25,000 bodily injury liability limit in exchange for a general release. During communications with the Lopez family's attorney, Allstate was also told that Nunez-Delgado was reporting physical and psychological symptoms after witnessing her husband's death. Her reported condition became part of the insurer's evaluation of claims resulting from the accident.
The family's attorney informed Allstate in writing that Nunez-Delgado was experiencing insomnia, headaches, high blood pressure, neck pain, depression, and other reported symptoms. Allstate requested a marriage certificate and medical records concerning her treatment. Settlement discussions continued while the insurer evaluated her claim. At that point, Allstate had not received medical bills documenting her claimed injuries.
A lawsuit was filed against Soto after the initial settlement efforts did not resolve the claims. The action included a wrongful death claim based on Giraldo Lopez's death and a negligent infliction of emotional distress claim brought by Nunez-Delgado. Allstate continued handling the claims under Soto's automobile policy while the lawsuit proceeded. Nunez-Delgado's medical condition and available coverage remained part of the claims process.
On September 29, Allstate notified its PIP department about Nunez-Delgado's claim, and a PIP file was opened. The following day, Allstate offered the full $50,000 bodily injury liability limit available for the accident. The proposal allocated $25,000 to Giraldo Lopez's Estate and $25,000 to Nunez-Delgado. It did not include the additional $10,000 in PIP benefits associated with Nunez-Delgado.
Soto was deposed on October 18 and answered questions about her personal assets. The Lopez family had authorized its attorney to resolve the claims for $65,000 in available policy benefits and also sought information showing whether Soto had collectible assets. The family had not authorized a resolution limited to the bodily injury liability limits. By October 24, Frank Lopez ended efforts to settle the claims with Allstate for the proposed combined amount, and the underlying liability litigation continued.
Soto and the claimants entered into a global settlement agreement on July 9, 2013. The agreement resolved the underlying liability claims through an agreed judgment against Soto. Nunez-Delgado also received an assignment of Soto's rights against Allstate. That assignment allowed her to pursue claims based on Allstate's handling of the underlying settlement process.
An amended consent final judgment awarded $1.15 million to Frank Lopez as personal representative of Giraldo Lopez's Estate and $350,000 to Nunez-Delgado. The combined judgment against Soto totaled $1.5 million. Her bodily injury liability coverage under the Allstate policy was limited to $50,000 per accident. The remainder of the consent judgment exceeded the available bodily injury liability coverage.
On October 15, Allstate paid $25,000 to the Estate and $25,000 to Nunez-Delgado under the bodily injury liability coverage. On October 29, it paid Nunez-Delgado an additional $10,000 in PIP benefits. Together with the $5,000 death benefit tendered in September 2011, the payments totaled $65,000. These payments were made after the earlier settlement discussions involving the same total amount had ended.
Frank Lopez, as personal representative of Giraldo Lopez's Estate, and Nunez-Delgado, individually and as Soto's assignee, sued Allstate in the U.S. District Court for the Southern District of Florida. They alleged that Allstate failed to settle the accident claims in a manner that protected Soto from an excess judgment. The claims proceeded under Florida common-law third-party insurance bad-faith principles. The litigation examined Allstate's investigation, communications, settlement negotiations, and handling of the available policy benefits.
Allstate sought summary judgment and argued, in part, that its failure to include Nunez-Delgado's $10,000 PIP benefits in an earlier settlement could not support bad-faith liability because those benefits had not yet become payable under Florida's PIP requirements. U.S. District Judge Marcia G. Cooke denied the motion. The court concluded that a reasonable jury could find, under the totality of the circumstances, that Allstate should have used the available benefits to obtain a settlement protecting Soto from excess exposure. The ruling allowed the bad-faith claims to proceed to trial without deciding whether Allstate had actually acted in bad faith.
Before trial, the district court considered several challenges to proposed expert testimony. The court limited portions of testimony from Rolando Diaz, M.D., Nunez-Delgado's treating physician, while allowing testimony concerning her condition during the period covered by the settlement negotiations. It also permitted plaintiffs' insurance claims-handling expert Donald Dinsmore to offer opinions concerning insurance practices while excluding opinions about applicable law and certain subjective characterizations of the parties' conduct. Allstate's proposed expert D. James Kadyk was excluded after the court found that he was not qualified to offer the proposed claims-handling opinions, had not demonstrated a reliable methodology for those opinions, and would not provide testimony that would assist the jury.
Following a seven-day jury trial, the Estate's claim and Nunez-Delgado's claim were considered separately. The jury unanimously found that Allstate did not act in bad faith in failing to settle the Estate's claim. It reached a different result for Nunez-Delgado and found that Allstate did act in bad faith in failing to settle her claim. Judgment was therefore entered for Allstate on the Estate's claim and for Nunez-Delgado on her individual bad-faith claim.
The district court entered an amended judgment awarding Nunez-Delgado $315,000 in damages. She also received $40,486.59 in prejudgment interest. Allstate challenged the judgment, while the plaintiffs filed a cross-appeal addressing other trial court rulings. The litigation then proceeded to the U.S. Court of Appeals for the Eleventh Circuit.
The Eleventh Circuit reviewed challenges involving the verdict structure, jury instructions, damages, prejudgment interest, and other district court rulings. In Lopez v. Allstate Fire & Casualty Insurance Co., 710 F. App'x 861 (11th Cir. 2018), the court found no reversible error. It affirmed the district court's final judgment, amended final judgment, and post-trial order. The verdict for Allstate on the Estate's claim and the judgment for Nunez-Delgado remained in place.
The plaintiffs offered Donald Dinsmore to testify about insurance claims-handling practices, including investigation, claim evaluation, communication, and settlement procedures. The court permitted his insurance claims-handling opinions but excluded opinions concerning applicable law and certain subjective characterizations of the parties' conduct.
Dr. Rolando Diaz treated Nunez-Delgado and was disclosed to testify about her medical condition. The court allowed testimony concerning her condition during the period when settlement remained possible but restricted opinions about later medical developments outside that period.
In auto liability insurance disputes, an auto liability insurance expert witness may address policy limits, claims evaluation, settlement practices, coverage provisions, and an insurer’s handling of third-party liability claims. This type of expert may also examine whether claim communications and settlement procedures were consistent with applicable insurance-industry practices, depending on the issues presented in the case.
Soto's policy provided $25,000 in bodily injury liability coverage per person and $50,000 per accident. It also provided up to $10,000 in PIP benefits per person and a $5,000 death benefit. The settlement discussions therefore involved benefits available under different portions of the same automobile insurance policy.
The $65,000 figure consisted of the $50,000 bodily injury liability limit, $10,000 in PIP benefits associated with Nunez-Delgado, and the $5,000 death benefit. Allstate offered the full $50,000 bodily injury limit on September 30, 2011, but that proposal did not include Nunez-Delgado's additional PIP benefits. The Lopez family also sought information concerning Soto's assets as part of the proposed resolution.
In this litigation, the district court applied Florida common-law third-party bad-faith principles that examined an insurer's investigation, evaluation of claims, communication with its insured, response to settlement opportunities, and efforts to resolve liability within available coverage. The parties disputed Allstate's conduct while the claims against Soto were being evaluated and negotiated. The court considered the totality of those circumstances rather than treating one payment, letter, or settlement offer as controlling.
Soto's bodily injury liability coverage was limited to $50,000 per accident. The amended consent judgment later entered against her totaled $1.5 million, including $1.15 million for Giraldo Lopez's Estate and $350,000 for Nunez-Delgado. The federal bad-faith action followed after the underlying claims had been resolved through that agreed judgment.
The district court considered proposed testimony concerning insurance claims handling and Nunez-Delgado's medical condition. Portions of Donald Dinsmore's and Dr. Rolando Diaz's testimony were permitted subject to evidentiary limits. D. James Kadyk's proposed testimony for Allstate was excluded in full after the court found deficiencies concerning his qualifications, methodology, and the usefulness of his opinions to the jury.
The negotiations following the September 2011 accident ended without a global settlement using the $65,000 in available policy benefits and the requested information concerning Soto's assets. The underlying wrongful death and emotional distress claims continued, and Soto later entered into an agreement that produced a $1.5 million consent judgment. Nunez-Delgado also obtained an assignment of Soto's rights against Allstate and later pursued those rights in federal court. After pretrial rulings and a seven-day jury trial, Allstate prevailed on the Estate's bad-faith claim, while Nunez-Delgado prevailed on hers and received $315,000 in damages plus $40,486.59 in prejudgment interest. The Eleventh Circuit affirmed the district court's judgments and post-trial rulings on February 7, 2018.
What happened in the accident that led to Lopez v. Allstate?
On September 6, 2011, Michelle Soto lost control of her vehicle and crashed into a bus-stop bench where Giraldo Lopez and Magaly Nunez-Delgado were waiting. Giraldo Lopez was struck and killed, while Nunez-Delgado witnessed the collision from a few feet away and later reported physical and psychological symptoms.
What did Allstate offer during the 2011 settlement negotiations?
Allstate tendered the Estate's $25,000 bodily injury liability limit and later offered the full $50,000 bodily injury limit for the accident. The September 30 proposal allocated $25,000 to the Estate and $25,000 to Nunez-Delgado but did not include her additional $10,000 in PIP benefits.
Why was $65,000 discussed as a settlement amount in Lopez v. Allstate?
The amount consisted of $50,000 in bodily injury liability coverage, $10,000 in PIP benefits associated with Nunez-Delgado, and a $5,000 death benefit. The Lopez family also sought information concerning Soto's assets during the settlement process, and the parties did not complete a global resolution on those terms.
What did the jury decide in the Allstate insurance bad-faith trial?
The jury found that Allstate did not act in bad faith in failing to settle Giraldo Lopez's Estate claim. It separately found that Allstate acted in bad faith in failing to settle Nunez-Delgado's claim, resulting in a judgment in her favor.
What was the final outcome of Lopez v. Allstate on appeal?
On February 7, 2018, the Eleventh Circuit affirmed the district court's final judgment, amended final judgment, and post-trial order. Nunez-Delgado's $315,000 damages award and $40,486.59 in prejudgment interest remained in place.
The plaintiffs offered Donald Dinsmore to testify about insurance claims-handling practices, including investigation, claim evaluation, communication, and settlement procedures. The court permitted his insurance claims-handling opinions but excluded opinions concerning applicable law and certain subjective characterizations of the parties' conduct.
Dr. Rolando Diaz treated Nunez-Delgado and was disclosed to testify about her medical condition. The court allowed testimony concerning her condition during the period when settlement remained possible but restricted opinions about later medical developments outside that period.
In auto liability insurance disputes, an auto liability insurance expert witness may address policy limits, claims evaluation, settlement practices, coverage provisions, and an insurer’s handling of third-party liability claims. This type of expert may also examine whether claim communications and settlement procedures were consistent with applicable insurance-industry practices, depending on the issues presented in the case.
Soto's policy provided $25,000 in bodily injury liability coverage per person and $50,000 per accident. It also provided up to $10,000 in PIP benefits per person and a $5,000 death benefit. The settlement discussions therefore involved benefits available under different portions of the same automobile insurance policy.
The $65,000 figure consisted of the $50,000 bodily injury liability limit, $10,000 in PIP benefits associated with Nunez-Delgado, and the $5,000 death benefit. Allstate offered the full $50,000 bodily injury limit on September 30, 2011, but that proposal did not include Nunez-Delgado's additional PIP benefits. The Lopez family also sought information concerning Soto's assets as part of the proposed resolution.
In this litigation, the district court applied Florida common-law third-party bad-faith principles that examined an insurer's investigation, evaluation of claims, communication with its insured, response to settlement opportunities, and efforts to resolve liability within available coverage. The parties disputed Allstate's conduct while the claims against Soto were being evaluated and negotiated. The court considered the totality of those circumstances rather than treating one payment, letter, or settlement offer as controlling.
Soto's bodily injury liability coverage was limited to $50,000 per accident. The amended consent judgment later entered against her totaled $1.5 million, including $1.15 million for Giraldo Lopez's Estate and $350,000 for Nunez-Delgado. The federal bad-faith action followed after the underlying claims had been resolved through that agreed judgment.
The district court considered proposed testimony concerning insurance claims handling and Nunez-Delgado's medical condition. Portions of Donald Dinsmore's and Dr. Rolando Diaz's testimony were permitted subject to evidentiary limits. D. James Kadyk's proposed testimony for Allstate was excluded in full after the court found deficiencies concerning his qualifications, methodology, and the usefulness of his opinions to the jury.
The negotiations following the September 2011 accident ended without a global settlement using the $65,000 in available policy benefits and the requested information concerning Soto's assets. The underlying wrongful death and emotional distress claims continued, and Soto later entered into an agreement that produced a $1.5 million consent judgment. Nunez-Delgado also obtained an assignment of Soto's rights against Allstate and later pursued those rights in federal court. After pretrial rulings and a seven-day jury trial, Allstate prevailed on the Estate's bad-faith claim, while Nunez-Delgado prevailed on hers and received $315,000 in damages plus $40,486.59 in prejudgment interest. The Eleventh Circuit affirmed the district court's judgments and post-trial rulings on February 7, 2018.
What happened in the accident that led to Lopez v. Allstate?
On September 6, 2011, Michelle Soto lost control of her vehicle and crashed into a bus-stop bench where Giraldo Lopez and Magaly Nunez-Delgado were waiting. Giraldo Lopez was struck and killed, while Nunez-Delgado witnessed the collision from a few feet away and later reported physical and psychological symptoms.
What did Allstate offer during the 2011 settlement negotiations?
Allstate tendered the Estate's $25,000 bodily injury liability limit and later offered the full $50,000 bodily injury limit for the accident. The September 30 proposal allocated $25,000 to the Estate and $25,000 to Nunez-Delgado but did not include her additional $10,000 in PIP benefits.
Why was $65,000 discussed as a settlement amount in Lopez v. Allstate?
The amount consisted of $50,000 in bodily injury liability coverage, $10,000 in PIP benefits associated with Nunez-Delgado, and a $5,000 death benefit. The Lopez family also sought information concerning Soto's assets during the settlement process, and the parties did not complete a global resolution on those terms.
What did the jury decide in the Allstate insurance bad-faith trial?
The jury found that Allstate did not act in bad faith in failing to settle Giraldo Lopez's Estate claim. It separately found that Allstate acted in bad faith in failing to settle Nunez-Delgado's claim, resulting in a judgment in her favor.
What was the final outcome of Lopez v. Allstate on appeal?
On February 7, 2018, the Eleventh Circuit affirmed the district court's final judgment, amended final judgment, and post-trial order. Nunez-Delgado's $315,000 damages award and $40,486.59 in prejudgment interest remained in place.
Auto Liability Insurance
Insurance Claims
Insurance Coverage
Liability Insurance
Liability Claims
Third Party Liability
Automobile Accidents
Claims Adjuster
Damages Calculations
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