Claims and Bad Faith Law Blog

BAD FAITH IN THE JUSTICE DEPARTMENT?

This article was originally published with the title, IN MERRICK GARLAND'S DEPARTMENT, PROTECTING 'CAREER YOUNG ATTORNEYS' MEANS "CYA," on Claims and Issues Blog, on Tuesday, June 29, 2021.

Part One, the first part.

Merrick Garland has been portrayed by the incoming administration as something he is not.  Demonstrably not.  To paraphrase the Acts of the Apostles, "you shall know them by their actions." 

          Not by what they say, or what others say about them.

          This is the first in a series.  In it, we will take a look together at the actual things being done by the current department of justice.  In the end, it is a puzzle why they continue to try to protect the things that were done by the previous regime.

    

 

   (Alexander Drago / Reuters)

           Our first example is the decision to continue the appeal to substitute the United States in the place of the former guy sued for defamation by E. Jean Carroll.  The former guy's regime, Bill Barr acting as Attorney General then, tried to substitute the United States for the F.G.  Federal Judge Lewis Kaplan thought about it, before he wrote a 61-page decision listing many, many reasons for denying the motion to substitute the United States to defend Ms. Carroll's defamation action.  It should not be forgotten that Ms. Carroll filed her defamation lawsuit in response to the F.G.'s vehement denial that he raped her.  (The F.G.'s vehemence included the charge that Ms. Carroll was lying, thus she filed the defamation lawsuit.)

           The F.G.'s Attorney General, Mr. Barr, filed an appeal from that ruling.  Then the F.G. and the A.G. left (kind of).  In came President Joe Biden and Merrick Garland to take their places.

 

 
   (Reuters)

           Merrick Garland decided to continue the appeal to substitute the United States for the former guy at taxpayer expense.  It is eye-opening to look at the lawyers who signed the reply brief attempting to substitute the U.S. for the F.G.  This is especially revealing after Mr. Garland's statements that he wants to protect 'career young attorneys' from thinking that what they did when they worked for Barr carries any consequences now.  Surely they must be protected, Mr. Garland said he believes.  Well, let's look at who is being protected now that we have looked at who is doing the protecting.

          The decision to continue the Barr justice department's appeal was taken by:

• BRIAN M. BOYNTON, Acting Assistant Attorney General;
• MARK R. FREEMAN;
• MARK B. STERN, and
• JOSHUA M. SALZMAN.

Three of these lawyers were at the Barr department of justice, following orders.

Three of these lawyers have worked at a law firm called WilmerHale.  So did MERRICK GARLAND. 

Three of these lawyers went to Harvard Law.  So did MERRICK GARLAND.

The three lawyers who went to Harvard Law all agreed to substitute the United States, at taxpayer expense, for the former guy in E. Jean Carroll's defamation lawsuit.  You might have expected something different from their conduct, considering that they each and all went to Harvard Law where they presumably took an Ethics course or two, but you would be wrong if you expected them to behave any differently than they actually did.

Parenthetically, Harvard Law comes up again here.  Judge Lewis Kaplan, who rejected the former guy's/Barr's motion to substitute, also went to Harvard Law.

           So here's the point.  It's not that WilmerHale or Harvard Law are either of them bad, per se.  The point instead is that neither Merrick Garland nor these lawyers are what they are portrayed to be.  "I was only following orders" was a defense that was rejected at Nuremberg circa 1945.  These men -- and they are all of them men, aren't they -- certainly do not need that defense for their actions.  It is equally certain that CYA is also a bad policy for the United States Department of Justice now.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

MORE ON BAD FAITH LAW REACHING OUT: EXCUSING REMOVAL DELAYS?

The law of bad faith reaches out to many areas of life and law.  See the article on other areas touched by bad faith law posted here on Monday, June 28, 2021.

              In CMR Constr. & Roofing, LLC v. Hartford Ins. Co. of Midw., No: 2:20-cv-695-JLB-NPM, 2021 WL 2632374 (M.D. Fla. June 25, 2021), a federal judge in Florida confronted another area where bad faith comes into play.  Hartford untimely removed a case from Florida State Court to U.S. District Court.  Hartford contended that the untimeliness of its removal should be excused because of the plaintiff's bad-faith conduct.  Accepting that argument in any case will make untimely removal an exception to the statute of limitations and so, in effect, make removal timely.

            Specifically in this case, Hartford contended that the plaintiff's delay in responding to certain discovery was in bad faith.  It was not until Hartford got the plaintiff's discovery responses, Hartford said, that it became clear to Hartford that there was a ground for removal.

            The District Judge disagreed on the evidence.  While the plaintiff's conduct was not commendable, the federal judge did not find that it sunk to the level of bad faith.  The Court accordingly granted the plaintiff's motion to remand the plaintiff's case to Florida State Court.  CMR, 2021 WL 2632374, at *3-*4.

Removal and remand cases are discussed in the context of insurance bad faith claims in third-party cases in 1 DENNIS J. WALL, LITIGATION AND PREVENTION OF INSURER BAD FAITH § 5:57 (3d ed. West Publishing Co., 2021 Supps.) & in first-party cases in 2 ID. § 11:23.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

THE LONG ARM OF BAD FAITH LAW.

In a Per Curiam Memorandum decision, a panel of Florida's Third District Court of Appeal spoke volumes by saying little.

    In Strems Law Firm, P.A. v. Citizens Prop. Ins. Corp., Nos. 3D20-919 & 3D20-920, 2021 WL 2559098 (Fla. 3d DCA June 23, 2021) (stated "NOT FINAL"), the panel PCA or "Per Curiam Affirmed" opinion cited to cases that tell a tale of the long reach of bad faith law.

    The panel opinion cited three Florida Supreme Court cases approvingly and gave a parenthetical for each one.  In particular, for one Supreme Court decision the Third District panel observed that “[A] trial court possesses the inherent authority to impose attorneys’ fees against an attorney for bad faith conduct.”  2021 WL 2559098, at *1 (emphasis added).

    The other Florida Supreme Court decisions cited in the PCA opinion involved Fla. R. Civ. P. 1.540, which concerns relief from judgments, and the inherent discretion of trial judges to dismiss actions and default parties for failure to comply with "discovery requirements."  2021 WL 2559098, at *1.

    It is worth remarking that of the three Supreme Court decisions cited in this opinion, the Supreme Court spoke of bad faith in two of them and that not one of the cited cases involved insurance.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

IMPLIED GOOD-FAITH DUTY, BUT STATUTORY ALLEGED, DISCOVERY NOT ALLOWED.

A U.S. Magistrate Judge in Colorado was not impressed enough with an alleged breach of good-faith duties to allow discovery into the supervision and incentives for the adjusters involved in investigating the claim.

          In American Ins. Co. v. Pine Terrace Homeowners Ass'n, No. 20-cv-00654-DDD-KMT, 2021 WL  2188707 (D. Colo.  2021) (Tafoya, USMJ) the Court first held that every insurance contract in Colorado has an implied duty of good faith.  Pine Terrace, 2021 WL 2188707, at *2 .  This may be dicta, however.

          The defendant homeowner's association alleged two counterclaims:  Breach of Contract and Statutory Bad Faith.  The homeowner's association in this case did not allege common law bad faith.

          The standard for statutory bad faith in Colorado precluded the discovery requested.  The Court ruled that where the standard for measuring extracontractual liability for statutory bad faith, as in Colorado, is whether the carrier's conduct is "reasonable" and not "why" did they  breach their good-faith duty, discovery was not allowed into the supervision and incentives given to the adjusters who handled the claim at bar.  See Pine Terrace, 2021 WL 2188707, at *3-*4 .

          The implied duty of good faith and fair dealing is recognized in virtually every court that has considered the question, including but not limited in most cases to insurance contracts.  See 1 DENNIS J. WALL, LITIGATION AND PREVENTION OF INSURER BAD FAITH § 1.01 (West Publishing Co. 3d ed. & 2021 Supplements).

          The question of discovery into alleged bad-faith claims handling is the subject of two Chapters in 1 id., Ch. 8, titled "Discovery From Insurers Concerning Their Handling of Third-Party Claims" addressing discovery from, by, and between insurance carriers in third-party bad faith cases, & 2 id., Ch. 12, titled "Discovery From and By Insurers," discussing the same issues addressed by the courts in first-party insurance bad faith cases.

Please see the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

WORK PRODUCT IMMUNITY IN FIRST-PARTY BAD FAITH (ARSON) CASES.

    "There are two divergent bodies of case law governing the application of the work product doctrine to documents prepared by insurers in investigating claims of fire loss thought to be caused by arson. One line of cases holds that litigation becomes reasonably anticipated—and, thus, documents are covered by the work product doctrine—when the insurer has an indication that the loss was caused by the insured committing arson.  [Citations omitted.]  The other line of case law creates a presumption that documents prepared prior to an insurer issuing a formal notice of intent to deny coverage are not covered by the work product doctrine, while documents prepared after such notice are covered by the work product doctrine.  [Citations omitted.]  Though the facts of each case vary, both lines of case law tend to establish that the work product doctrine kicks in when 'the probability of litigating the claim is substantial and imminent.'”  So said a Federal Judge in the Southern District of West Virginia in the case of Javins v. Westfield Ins. Co.,  No. 2:20-cv-00698, 2021 WL 2188751, at *3 (S.D. W. Va. May 28, 2021).

    It has not been said better very often, so I quote this passage here in its entirety.  When it's good, leave it alone to be good, whatever "it" may be.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

IT'S NOT THE LAWYERS SO MUCH AS RELIEF THEY REQUEST.

I was wondering how the plaintiffs got rulings so promptly in two cases recently, one in the Sixth Circuit Court of Appeals and the other in the Northern District of Texas.  In both cases, the plaintiffs were challenging federal laws that benefitted other groups of people to which they did not belong; the plaintiffs wanted federal money to go to them.

          They got quick rulings on their requests.  I was wondering about that, as I say.  I do not think it was necessarily because they had better lawyers, as much as it was about the kind of relief they requested.

          The plaintiffs requested preliminary injunctions.  Requesting that kind of relief ordinarily galvanizes a judge into action.  This is in contrast to, say, trying to get a court to enforce a Congressional subpoena, which as we have seen can take years, and it is in contrast to attempting to have a judge apply either of the emoluments clauses of the United States Constitution, which as we have seen may never happen at all.

          These two cases are not the end of plaintiffs challenging federal laws and policies in Courts; they are the beginning.  If the current administration including the current justice department is going to stop losing, they are going to have to be strategic.

          First, they must consider going on the offensive and file suit, whenever the opportunity arises, to enforce the laws instead of waiting for laws to be challenged.

          They should also consider the relief they request, and how long it will take to achieve their purpose in filing suit.  Let the plaintiffs in these cases be guides if not mentors, exactly; is there an opening to file suits to request preliminary injunctive relief?

          Say requesting a preliminary injunction to stop a fraudit from using actual ballots cast in federal elections, which as I understand it is against the law during this short timeframe since the November 2020 election?

          If someone wants to be more successful in litigation, be more strategic.  Your probable adversaries will be more strategic in filing lawsuits.  To that end, expect more lawsuits to be filed in the Northern District of Texas.  Be ready, by filing first in a forum which you, not they, select.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

WITHHOLDING EQUALITY WHILE DEFENDING MAJORITY RULE. OF ECONOMICS, THAT IS.

The American Rescue Plan Act provides a limited amount of money for restaurants to recover from losses they suffered from COVID-19.  The money that the Act provides to get restaurants back on their feet has been called a restaurant revitalization fund.

          Yes, I know, the 'company line' is that the American Rescue Plan Act involves a lot of money, and it does.  In the case of aid to recovering restaurants, however, the funds provided  in the Act are limited and, some say, too small to meet the needs.

          In May, five federal judges considered complaints from a couple of businesses that claimed they were discriminated against.  They claimed that they suffered from discrimination under the American Rescue Plan Act because the Small Business Administration (SBA) paid out the available revitalization funds first to so-called "priority" restaurants whereas they themselves were "non-priority" for the money that the Act makes available.

          "Priority" restaurants under the Act are owned by women, by veterans, or by "socially and economically disadvantaged" people.  The plaintiffs claimed that they were discriminated against because they are not women and not socially or economically disadvantaged, i.e., because they are White males who are socially or economically advantaged, in other words.  It is unclear, frankly, whether any of the plaintiffs are or have ever been veterans.

          The problem at the center of both of their two cases was the same:  Under the American Rescue Plan Act, the restaurant revitalization funds were supposed to be released for the first 21 days only to restaurants owned by women, by veterans, or by people who are socially or economically disadvantaged.  After that, the Act provided that all the applicants could receive the money whether they were prioritized for the first 21 days or not.  This was the problem at the center of the plaintiffs' arguments in both cases to all five judges:  The plaintiffs were afraid that they would not get money.

          Whatever you may end up thinking about the merits of these decisions, one way or the other, remember what the cases were about:  The plaintiffs were afraid that they would not get their money.  All the idealistic-sounding pronouncements that will certainly come from the winning parties cannot obscure that central fact:  They sued because they wanted to get their money.

          That shouldn't obscure how close a thing it was, either.  The same people who want to pose as nothing but idealists did not win by much at all.  Five federal judges considered these complaints.  Three liked the complaints, and thought that they were good.  Two did not.

          Three to two.  That's how the judges lined up their votes on the matter in two separate cases.

          What's more, you will almost certainly hear that these decisions should be seen as a triumph for even-handed justice.  Except it seems that the thing was not handled very evenly in either case.  In both of these cases, the opinion blocking the SBA from carrying out the restaurant revitalization fund written in the Act, was in turn written by a person who was either on or, in at least one case, led a central committee for the political party that opposed the American Rescue Plan Act in the first place. 

          It is also important to put the rulings in their proper context to know more about at least one of the judges.  The judge in the Texas case is named Reed O'Connor.  You may remember his name from his opinion that has received heavy criticism for its logic, or absence of it some say, in ruling that the Affordable Care Act is unconstitutional because it imposes no penalties.

          In addition, it is worth noting that the plaintiffs in both cases challenging the SBA are represented by, among others, an interesting cast of characters.  The plaintiff in one case is from Tennessee and is represented in part by an organization from Wisconsin which exists for the purpose of pushing litigation against the interests of people like women and in general against people who are socially or economically disadvantaged -- the very people involved here.

          In the other lawsuit, the one filed in Texas, the plaintiffs are represented by among others, America First Legal Foundation.  The founders of the foundation in this case are one Stephen Miller and several other departed -- or so we thought -- former officials of the prior regime.

          In short, maintaining power by claiming the idealism of disinterested equality in an overwhelming victory, that's how the story will be sold.  How in character for these men (and they are all men, did you notice?).

          Now you and I both know the real story of these two lawsuits.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

STOPPING LOW-INCOME ACCESS TO BROADBAND: THIS CANNOT WAIT.

In New York St. Telecomm's Ass'n v. James, No. 2:21-cv-2389 (DRH) (AKT), 2021 WL 2401338 (E.D.N.Y. June 11, 2021), a Senior District Judge brought minorities' broadband access to an abrupt halt.  He ruled before the merits and entered a preliminary injunction blocking enforcement of a New York State law.

          The New York Affordable Broadband Act would have required the plaintiffs on "June 15, 2021 to offer qualifying low-income costumers [sic] high-speed broadband service at or below certain price ceilings."  Telecomm's Ass'ns, 2021 WL 2401338, at *1.  The Judge's preliminary injunction on June 11, 2021 came just in time for the plaintiffs.

          The plaintiffs could not tolerate offering qualifying low-income customers high-speed broadband service at or below certain price ceilings.  Even during a plague.  Perhaps especially during the COVID plague.

          The plaintiffs are "a group of trade associations whose members provide broadband internet service to New Yorkers[.]"  Telecomm's Ass'ns, 2021 WL 2401338, at *1. 

          The Court ruled that the New York State law is preempted by federal law which regulates the rates the plaintiffs charge.  This is the filed rate doctrine in new clothes.  This ruling means that, having regulated the rates of broadband internet service, only the federal government can act to require that any low-income customers be offered broadband service at any other rate.

          From the perspective of the telecommunications industry, this preliminary injunction could not wait.  From the perspective of this author, this article could not wait and that is why it is posted on an unusual day for publication on this blog, a Tuesday.  Reasonable accommodations are often a requirement of living.

          And of the law. 

The filed rate doctrine is discussed in 2 DENNIS J. WALL, LITIGATION AND PREVENTION OF INSURER BAD FAITH § 11:26 (3d ed. West Publishing Co., 2021 Supps.).

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

WHO, EXACTLY, DOES JUSTICE REPRESENT? PART TWO

A POSTSCRIPT:  The rest of the story.  Part of the rest, anyway.

Rights and Responsibilities.  (Florida Dep't of Agriculture & Consumer Services /  Gridview_imagefull)

The Federal Judge presiding over the Sweet v. DeVos case in the Northern District of California has held that Ms. DeVos has to sit for a deposition. 

          The Judge based his ruling at least in part on the bad faith of the government in disrupting the processing of claims to student debt relief:    "U.S. District Judge William Alsup found evidence of bad faith in the agency’s stated reasons for an 18-month halt in processing debt relief claims [which], among other factors, creates an extraordinary circumstance that warrants making DeVos sit down for a three-hour deposition."  Nicholas Iovino, Betsy DeVos Ordered to Testify in Student Borrower Class Action, COURTHOUSE NEWS, online May 20, 2021.

          Updating my article that posted this morning, "[o]n February 8, 2021 -- 19 days after the Inauguration of President Joe Biden -- Brian M. Boynton filed a motion to quash a subpoena for the deposition of Betsy DeVos."  Mr. Boynton is a new hire helping to run the Biden Justice Department under Merrick Garland.

          And, to say again, Mr. Boynton filed a motion to quash the deposition of the former regime's Betsy DeVos.

          He lost.  The motion was denied.  Absent Mr. Boynton's anticipated appeal on behalf of Ms. DeVos, she will have to sit for her deposition, under oath.  So far, Justice has prevailed in this case, but the department of justice has not.

Thanks to Margaret O'Grady, Esquire at Harvard who is a counsel of record in the Sweet v. DeVos case, and to Ms. Katie Ward of CTPBoston, for the linked Courthouse News Service reporting.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

WHO, EXACTLY, DOES JUSTICE REPRESENT?

Rights and Responsibilities.  (Florida Dep't of Agriculture & Consumer Services /  Gridview_imagefull)

On February 8, 2021 -- 19 days after the Inauguration of President Joe Biden -- Brian M. Boynton filed a motion to quash a subpoena for the deposition of Betsy DeVos.

           Mr. Boynton filed his motion in the Southern District of Florida, where DeVos was then "a part-time resident."  That was one of the places where, arguably, venue was proper for Boynton's motion to quash.  The case in which Betsy DeVos was subpoenaed for deposition is pending in the Northern District of California.

           Parenthetically, I cannot find an order granting or denying the motion, and I cannot find any evidence that Ms. DeVos has  been deposed.  I have today emailed the lead attorney who requested this deposition, Margaret E. O'Grady, Esquire and if and when I receive her Reply, I will write about it here.

          Back to Mr. Boynton.  More recently, on June 7, 2021 Brian Boynton filed a reply brief for the United States to intervene for the former guy in his appeal from an order allowing E. Jean Carroll's defamation lawsuit to go forward in New York State Court.  Her defamation lawsuit had been pending in state court before the former guy's Barr removed the case to federal court.

          Mr. Boynton was reportedly hired away from a large law firm with experience in representing corporate clients, in order to assist Merrick Garland in running the Justice Department.

          The actions discussed here, and other actions known and unknown, raise urgent questions.  First:  Who, exactly, does Justice represent?

          Next, why is it in the interest of the United States not to have the testimony of Betsy DeVos under oath?

          How is it that any lawyer can argue, without consequence, that denying a rape and demeaning the victim is a part of the official duties of a President of the United States?

          I did not expect to be asking any of these questions with Merrick Garland replacing Bill Barr and Joe Biden replacing the former guy. 

          Did you?

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

COURTS WRITE LAW, OVERRIDE CONSTITUTION, FOR "SENSITIVE BUSINESS INFORMATION."

(NASA)

Courts are tending to keep documents and testimony a secret just so long as the parties claim it is "sensitive business information."  See, e.g., M3 USA Corp. v. Summer Qamoum, No. 20-2903 (RDM), 2021 WL 2324753, at *7 (D.C.D.C. June 7, 2021) ("The Court also entered a stipulated protective order, permitting the parties to safeguard their sensitive business information. Dkt. 20.").

          When entering a secrecy order, i.e., a protective order such as under Federal Rule of Civil Procedure 26(c), Courts have wide discretion.  However they do not have discretion to override the presumption of public access to Court records at will.

          Courts have to accommodate that presumption, to recognize it and to apply certain safeguards when the interests are balanced in favor of secrecy, including to limit disclosure rather than to bar disclosure entirely unless the case is so unique that no disclosure is required.  The presumption of public access to Court records is a presumption which comes from both the United States Constitution and common law (even though, in the federal system, there is not supposed to be such a thing as common law).

          Keeping "sensitive business information" confidential is really a creation of the lawyers for large corporations which want to keep such information a secret from the public.  Large corporations would face a risk of losing business otherwise.  Needless to say, "sensitive business information" is not protected from disclosure either by the Constitution or by Rules of Procedure; rather, it is protected from disclosure by a swiftly growing number of Courts and stipulations, as in this case. 

          For recent restrictions on secrecy orders, see for example the articles posted here on May 24 and on May 26, 2021.

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.

"A MULTITUDE OF CASES" DETERMINES COVID COVERAGE IN CASE.

In HT-Seattle Owner LLC v. Am. Guar. & Liab. Ins. Co., NO. 2:21-cv-00048-BJR, 2021 WL 2206480 (W.D. Wash. June 1, 2021), policyholders argued that coverages aside from those that had been litigated in Washington State potentially provided insurance coverage to COVID-related losses.   The District Judge handling all these cases disagreed:

These provisions, however, all require direct physical loss or damage to covered property to trigger coverage. See Compl., Ex. A, Dkt. No. 1-1 at 41 (Insurance Agreement), 47 (Property Damage), 51(Time Element), 53 (Extra Expenses), 85 (Covered Cause of Loss). Therefore, given the Court's conclusion that COVID-19 does not cause physical loss or damage, these provisions fail to provide coverage.

HT-Seattle, 2021 WL 2206480, at *1 (citations omitted).

          The Court pointed out that this case "is one amongst a multitude of cases across the United States in which a business seeks coverage for income lost due to the COVID-19 pandemic from their insurance company."  HT-Seattle, 2021 WL 2206480, at *1.  The Western District of Washington assigned all such insurance coverage cases to the District Judge who decided this case.  She, in turn, "consolidated the earliest of these actions into ten cases."  She reached the same ruling in all those cases because they all had the same policy language in their Insuring Agreements, i.e., in their coverage grants:

This Court recently published an Order in those cases holding there was no coverage for losses due to COVID-19. See Nguyen, et al. v. Travelers Cas. Ins. Co., et al., No. 20-cv-00597, 2021 WL 2184878 (W.D. Wash. May 28, 2021). The Court held that in all of the relevant policies “direct physical loss of or damage to” covered property was required to trigger coverage and COVID-19 did not cause physical loss or damage. Id. at *9–*13. Additionally, the Court held that the plaintiffs’ Extra-Contractual Claims should be dismissed along with their Contractual Claims where they failed to identify independent grounds apart from unreasonable denial of coverage. Id. at *13–*14.

HT-Seattle, 2021 WL 2206480, at *1 (footnote omitted).   

          Once again, the Court also ruled that because there was no viable coverage claim, there was no cognizable claim for insurer bad faith, either.  HT-Seattle, 2021 WL 2206480, at *2.

Cases involving the dismissal of bad faith claims in COVID coverage cases after a holding that there is no coverage for COVID-related losses, are reviewed in Volume 2 of Dennis J. Wall, Litigation and Prevention of Insurer Bad Faith § 9:14 (3d ed. Thomson Reuters West, 2021 Supplements forthcoming).  See in addition 2 id. §  9:31 (discussing basic coverage issues common to Chinese Drywall, COVID, and other property insurance cases).

Please read the disclaimer.  ©2021 Dennis J. Wall.  All rights reserved.