RESPONSE TO COVERAGE POSITION / DENIAL

To: [Carrier Claims Adjuster/Address/Email]
From: [Insured / Counsel for Insured]
Date: [DATE]
Policy No(s).: [POLICY NUMBER(S)]
Claim: [CLAIM NAME/NUMBER]

1. ACKNOWLEDGMENT

• We acknowledge receipt of your letter dated [DATE] denying/limiting coverage based on [Exclusions/Conditions cited].

2. FACTUAL CORRECTIONS

• Your letter states [misstated fact]; the correct fact is [correct fact] (see [Exhibit/Attachment]).
• Additional facts relevant to coverage: [List].

3. POLICY INTERPRETATION AND COVERAGE POSITION

• Coverage grant: [Cite insuring agreement and how claim fits].
• Exclusions cited: [List] do not apply because [reasons: exceptions, carve-backs, inapplicable elements, ambiguous terms].
• Conditions: All notice/cooperation/consent conditions satisfied or waived; retro date and policy period satisfied.
• Duty to defend/advance applies because [potential for coverage / broad duty to defend].

4. REQUESTED ACTION

• Withdraw denial/limitation; confirm defense and indemnity coverage (or advancement) in writing.
• Assign or approve defense counsel [NAME/FIRM]; commence defense/advancement within [X] days.
• If you maintain your position, provide a full and specific explanation with supporting policy language and facts.

5. RESERVATION OF RIGHTS (INSURED)

• Insured reserves all rights, including to pursue statutory/extra-contractual remedies where applicable. No waiver of any rights or acceptance of your position.

6. ATTACHMENTS

• [Coverage analysis excerpts, timeline, exhibits correcting facts, prior correspondence]

Please respond in writing by [DATE].

Signed:
[NAME/TITLE or COUNSEL NAME]
[INSURED ENTITY / LAW FIRM]
[CONTACT INFO]