INSURANCE BAD FAITH DEMAND LETTER – ALABAMA

To: [Insurance Company Name, Claims Department Address]
From: [Insured/Claimant Name, via Counsel if applicable]
Date: [DATE]
Claim Number: [CLAIM NUMBER]
Policy Number: [POLICY NUMBER]
Insured: [INSURED NAME]
Date of Loss: [DATE OF LOSS]
Type of Coverage: [e.g., Homeowner's, Auto, Commercial Property]

1. INTRODUCTION AND PURPOSE

This letter constitutes a formal demand to [INSURANCE COMPANY] ("Insurer") to immediately and fully pay all benefits owed under the above-referenced policy. Insurer's continued delay and/or denial of this claim lacks any reasonable or arguable basis and constitutes bad faith under Alabama law.

2. FACTUAL BACKGROUND

• Date of Loss: On or about [DATE], [INSURED] suffered [describe loss: property damage, bodily injury, business interruption, etc.].
• Timely Notice: Insurer was promptly notified of the loss on [DATE].
• Cooperation: Insured has fully cooperated with all reasonable requests, including providing [documentation submitted: proof of loss, estimates, medical records, etc.].
• Coverage: The loss is clearly covered under the Policy's insuring agreement for [coverage type] with limits of [$LIMITS].

3. CLAIM HISTORY AND INSURER'S CONDUCT

• [DATE]: Claim submitted with all required documentation.
• [DATE]: [Describe insurer's response: acknowledged claim, requested additional info, etc.]
• [DATE]: [Describe further delays, denials, lowball offers, or unreasonable conduct]
• To date, Insurer has [failed to pay / underpaid by $X / wrongfully denied] benefits clearly owed under the Policy.

4. LEGAL BASIS – ALABAMA BAD FAITH

Under Alabama law, an insurer commits bad faith when it intentionally refuses to pay a claim when there is no lawful basis for the refusal and the insurer has actual knowledge of that fact. State Farm Fire & Cas. Co. v. Slade, 747 So. 2d 293 (Ala. 1999); National Sec. Fire & Cas. Co. v. Bowen, 417 So. 2d 179 (Ala. 1982).

Insurer's conduct in this matter demonstrates:
- [ ] Unreasonable delay in investigating and/or paying the claim;
- [ ] Denial without reasonable basis;
- [ ] Failure to conduct a fair and unbiased investigation;
- [ ] Misrepresentation of policy provisions or Alabama law;
- [ ] Lowball offer not supported by the evidence.

5. DAMAGES

Insured demands payment of:
- Policy benefits owed: [$AMOUNT]
- Consequential damages (if applicable): [$AMOUNT]
- Total Demand: [$TOTAL]

In the event litigation becomes necessary, Insured will also seek:
- Punitive damages under Ala. Code § 6-11-20 (available upon clear and convincing evidence of oppression, fraud, wantonness, or malice);
- Reasonable attorney's fees;
- Pre- and post-judgment interest;
- Costs of suit.

6. DEMAND AND DEADLINE

Insurer is hereby demanded to:
1. Pay the full amount of [$AMOUNT] in policy benefits; and
2. Provide written confirmation of payment.

Response Deadline: [DATE – typically 15-30 days]

Failure to respond satisfactorily by the deadline will result in the immediate filing of a lawsuit asserting claims for breach of contract, bad faith, and punitive damages.

7. PRESERVATION NOTICE

Insurer is hereby directed to preserve all documents, communications, and electronically stored information related to this claim, including but not limited to the complete claim file, all internal communications, adjuster notes, supervisor reviews, and any reserve information.

8. ATTACHMENTS

• Exhibit A: Policy declarations page
• Exhibit B: Proof of loss / damage documentation
• Exhibit C: Claim correspondence history
• Exhibit D: Estimates / invoices / medical records (if applicable)

Signed:
[Name]
[Title / Attorney for Insured]
[Address]
[Phone / Email]