#1) Delay: Play with the paperwork, ask for the same information many times,
#2) Deny: When #1 ends then Deny the claim,
#3) Defend: Make the policy holder take you to court, if you lose appeal it and keep it on appeal as long as possible.
In an amendment to the original complaint the owner of the vandalized bookstore in Sicklerville, NJ, now adds five counts to their $325,000 claim and alledge that both the Franklin Lakes (NJ) insurance company (Western World) and their Montivale (NJ) agents (Jimcor Agencies):
* Failed/Refused to make payments to them under the terms of the policy,
* Breached their duty of good faith and fair dealing with Plaintiff,
* Without reasonable basis acted in bad faith,
* Engaged in wrongful and tortious acts in violation of the NJ Consumer Fraud Act and the Insurance Trade Practices Act, by committing both affirmative misrepresentation and knowing omissions in violation of said Acts,
* Refused to pay benefits after receiving all pertinent information necessary to evaluate the claim, demanding multiple submissions of the same materials,
* Compelled the Plaintiff to initiate litigation and incur out of pocket legal fees to obtain benefits of their insurance policy,
* Breached their advertised claims of protecting their insured by providing coverage while at the same time refusisng to pay the claim,
* Failed to comply with terms and conditions of the policies they wrote,
* Committed and engaged in Unconscionable commercial practices, deception, fraud, false promises, misrepresentation and thus caused Plaintiff financial damage and loss,
The Plaintiff asks for a jury trial and demands compensatory damages, punitive damages, attorney fees and the costs of the suit.