COVERAGE POSITION / DENIAL RESPONSE TOOLKIT (POLICYHOLDER)

PRACTICE NOTE: This universal template provides a comprehensive framework for responding to an insurer's coverage denial or adverse coverage position. State-specific versions with tailored statutory citations, bad faith standards, and remedies are available for AK, AL, AR, AZ, CA, CO, FL, NY, and TX. Always use the state-specific version where available, as bad faith law, statutory remedies, and procedural requirements vary significantly by jurisdiction.

PART ONE: FORMAL DENIAL RESPONSE LETTER

[LAW FIRM LETTERHEAD]

[__/__/____]

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED, AND EMAIL

[________________________________]
[________________________________]
[________________________________]
[________________________________]

Re: Response to Coverage Denial
Insured: [________________________________]
Policy Number(s): [________________________________]
Claim Number: [________________________________]
Date of Loss: [__/__/____]
Your Denial Letter Dated: [__/__/____]

Dear [________________________________]:

This firm represents [________________________________] ("Insured") in connection with the above-referenced claim under Policy No. [________________________________] issued by [________________________________] ("Insurer" or "Company"). We write in response to your letter dated [__/__/____] in which you denied coverage for the above-referenced claim. For the reasons set forth below, we believe your denial is without merit and must be reversed.

I. IDENTIFICATION OF DENIAL AND STATED BASES

Your denial letter states that coverage is denied based on the following grounds:

1. [________________________________]
2. [________________________________]
3. [________________________________]

We address each stated basis for denial below and demonstrate that none provides a valid basis for denying coverage.

II. FACTUAL CORRECTIONS

Your denial letter contains the following factual errors that must be corrected:

Misstatement 1: Your letter states: "[________________________________]"
Correct Fact: [________________________________] (See Exhibit [____])

Misstatement 2: Your letter states: "[________________________________]"
Correct Fact: [________________________________] (See Exhibit [____])

Misstatement 3: Your letter states: "[________________________________]"
Correct Fact: [________________________________] (See Exhibit [____])

These factual errors are material to the coverage determination and suggest that the claim file was not thoroughly reviewed before the denial was issued.

III. COVERAGE ANALYSIS AND REBUTTAL

A. The Insuring Agreement Provides Coverage

The Policy's insuring agreement provides, in relevant part:

"[________________________________]"
(Policy, Section [____], p. [____])

The claimed loss falls squarely within this insuring agreement because:

1. [________________________________]
2. [________________________________]
3. [________________________________]

Under well-established principles of insurance policy interpretation, the insuring agreement must be given a broad construction in favor of the insured, while exclusions must be strictly construed against the insurer. See, e.g., [________________________________] (applicable jurisdiction case citation).

B. The Cited Exclusion(s) Do Not Apply

Your denial relies on the following policy exclusion(s):

"[________________________________]"
(Policy, Section [____], p. [____])

This exclusion does not bar coverage for the following reasons:

☐ The exclusion is inapplicable on its face. The factual circumstances of this loss do not satisfy the elements of the exclusion because [________________________________].

☐ An exception to the exclusion restores coverage. Even if the exclusion otherwise applied, the following exception applies: "[________________________________]" (Policy, Section [____], p. [____]).

☐ The exclusion is ambiguous and must be construed in favor of coverage. The term "[________________________________]" as used in the exclusion is susceptible to more than one reasonable interpretation. Under the doctrine of contra proferentem, ambiguous policy language must be construed against the insurer as drafter.

☐ The insurer bears the burden of proving the exclusion applies. It is a fundamental principle of insurance law that the insurer bears the burden of establishing that an exclusion applies. The insurer has failed to meet this burden because [________________________________].

☐ The exclusion violates public policy or applicable statute. The application of this exclusion as the insurer proposes would violate [________________________________].

☐ The efficient proximate cause doctrine applies. Even if an excluded peril contributed to the loss, the efficient proximate cause of the loss was a covered peril, specifically [________________________________]. Under the efficient proximate cause doctrine recognized in this jurisdiction, coverage applies.

C. Policy Conditions Have Been Satisfied

☐ Timely Notice: Notice of the claim was provided on [__/__/____], which is within any applicable notice period. In most jurisdictions, the insurer must demonstrate actual prejudice from late notice before it may deny coverage on late notice grounds.

☐ Cooperation: The Insured has cooperated fully with the investigation, including [________________________________].

☐ Proof of Loss: A sworn proof of loss was submitted on [__/__/____], or the insurer waived the requirement by [________________________________].

☐ Examination Under Oath: The Insured submitted to an examination under oath on [__/__/____] and cooperated fully.

☐ Other Conditions: [________________________________]

D. Duty to Defend (Liability Policies)

☐ If this claim involves a third-party liability policy, the insurer owes a duty to defend. The duty to defend is broader than the duty to indemnify. If the complaint alleges facts that potentially fall within coverage, the insurer must defend the entire action. The underlying complaint alleges [________________________________], which triggers the duty to defend because [________________________________].

IV. DEMAND

Based on the foregoing, we demand the following:

1. Withdraw the denial and confirm in writing that the claim is covered under the Policy;
2. Pay the claim in the amount of $[________________________________] within [____] days;
3. ☐ Assign or approve defense counsel [________________________________] and commence defense immediately (for liability claims);
4. ☐ Pay for repairs/replacement as documented in the attached estimate of $[________________________________];
5. Provide a complete copy of the claim file, including all adjuster notes, correspondence, internal memoranda, and coverage opinions, as required by applicable law;
6. If you continue to maintain your denial, provide a detailed written explanation citing specific policy language and factual findings supporting each basis for denial.

V. RESERVATION OF RIGHTS (INSURED)

The Insured reserves all rights, remedies, and defenses available under the Policy, at law, and in equity, including but not limited to:

• The right to pursue a breach of contract action for unpaid benefits
• The right to pursue statutory and common law bad faith claims
• The right to seek consequential damages, punitive damages, and attorney fees as permitted by applicable law
• The right to file a complaint with the state insurance department
• The right to seek pre-judgment interest on all amounts owed

Nothing in this letter constitutes a waiver of any right or an acceptance of any position taken by the Insurer.

VI. CONCLUSION

Please respond to this letter in writing no later than [__/__/____]. If we do not receive a satisfactory response by that date, we will take all appropriate action to protect our client's interests, including but not limited to filing a complaint with the state department of insurance and commencing litigation.

Respectfully,

[________________________________]
[________________________________]
[________________________________]
[________________________________]
[________________________________]

Enclosures:
- Exhibit A: [________________________________]
- Exhibit B: [________________________________]
- Exhibit C: [________________________________]

PART TWO: COVERAGE ANALYSIS FRAMEWORK

Use the following systematic approach to analyze a coverage denial before drafting the response letter.

Step 1: Insuring Agreement Analysis

☐ Identify the specific insuring agreement at issue
☐ Parse the insuring agreement into its elements
☐ Determine whether each element is satisfied:

☐ Note any ambiguous terms requiring interpretation
☐ Research applicable case law interpreting similar insuring agreement language

Step 2: Exclusion Analysis

☐ Identify each exclusion cited in the denial
☐ Remember: the insurer bears the burden of proving the exclusion applies
☐ Parse each exclusion into its elements:

Exclusion: [________________________________]

☐ Determine whether the exclusion has been applied to similar facts in case law
☐ Note any ambiguities in the exclusion language

Step 3: Exception to Exclusion Analysis

☐ Identify all exceptions to the cited exclusion(s)
☐ Remember: the insured bears the burden of proving an exception applies
☐ Determine whether any exception restores coverage:

Step 4: Condition Compliance Analysis

☐ Identify all policy conditions precedent to coverage
☐ Determine compliance with each condition:

☐ For any non-compliance, determine whether the insurer must show prejudice
☐ Determine whether the insurer waived or is estopped from asserting the condition

Step 5: Causation Analysis

☐ Identify all causes of the loss
☐ Determine which causes are covered and which are excluded
☐ Apply the applicable causation doctrine:
- ☐ Efficient proximate cause (majority rule)
- ☐ Concurrent causation
- ☐ Anti-concurrent causation clause in policy
☐ Research jurisdiction-specific causation rules

PART THREE: COMMON DENIAL REBUTTAL ARGUMENTS

3.1 Late Notice Denial

Insurer's position: Coverage denied due to late notice of claim/occurrence.

Rebuttal arguments:

☐ Notice was timely under the policy terms. Notice was given on [__/__/____], which is within [____] days of the occurrence/loss/knowledge of claim.

☐ The "as soon as practicable" standard is satisfied. Courts interpret this to require notice within a reasonable time under all the circumstances, not immediate notice. Factors include the severity of the injury, the insured's physical condition, and whether the insured reasonably believed the incident might not give rise to a claim.

☐ The insurer must demonstrate actual prejudice. In most jurisdictions, the insurer cannot deny coverage for late notice unless it demonstrates actual prejudice from the delay. The insurer has not demonstrated prejudice because [________________________________].

☐ The notice-prejudice rule applies as a matter of law. [Insert applicable jurisdiction statute or case law.]

☐ The insurer received actual notice from another source. The insurer received timely notice of the claim from [________________________________] on [__/__/____], which constitutes sufficient notice.

☐ The insurer waived the late notice defense by conducting an investigation and adjusting the claim before raising the defense.

3.2 Exclusion-Based Denial

Intentional Act Exclusion

☐ The insured did not intend the resulting harm, only the act. The intentional act exclusion requires intent to cause the specific injury or damage, not merely intent to perform the act that led to the injury.

☐ The "inferred intent" doctrine does not apply where the harm was not substantially certain to result from the act.

☐ The severability clause means each insured's intent is evaluated separately.

Pollution/Contamination Exclusion

☐ The loss was caused by a "sudden and accidental" event, which falls within the exception to the pollution exclusion (if applicable to the policy form).

☐ The substance at issue is not a "pollutant" or "contaminant" within the meaning of the exclusion as applied to the specific facts.

☐ The "absolute" pollution exclusion, if applicable, should not be extended beyond traditional environmental pollution.

Earth Movement/Subsidence Exclusion

☐ The loss was caused by [________________________________], not "earth movement" as defined in the policy.

☐ The ensuing loss provision applies because [________________________________].

☐ The earth movement was caused by a covered peril (e.g., water damage causing subsidence).

Wear and Tear / Maintenance Exclusion

☐ The loss was caused by a sudden and accidental event, not gradual deterioration.

☐ The ensuing loss provision provides coverage for the resulting damage even if the initial cause was a maintenance issue.

☐ The insurer conflates the cause of loss with the resulting damage.

Business / Commercial Use Exclusion

☐ The use in question does not constitute "business" or "commercial" use as defined in the policy.

☐ The incidental business use exception applies.

3.3 Policy Condition Failure

Failure to Submit Sworn Proof of Loss

☐ The proof of loss was submitted on [__/__/____] and was timely.

☐ The insurer waived the proof of loss requirement by failing to request one, or by conducting its own investigation without requesting it.

☐ The proof of loss was substantially compliant with the policy requirements.

☐ The insurer failed to provide the required proof of loss forms.

Failure to Cooperate

☐ The insured has cooperated fully with the investigation, including [________________________________].

☐ Any non-cooperation was not willful and did not materially prejudice the insurer.

☐ The insurer must demonstrate actual and substantial prejudice from any alleged non-cooperation.

Failure to Submit to Examination Under Oath

☐ The insured appeared for and completed the EUO on [__/__/____].

☐ The insurer's scheduling demands were unreasonable, and the insured proposed reasonable alternatives.

☐ The insured's assertion of privilege to specific questions does not constitute a refusal to submit to the EUO.

3.4 Misrepresentation / Fraud Denial

☐ There was no material misrepresentation in the application. The statement at issue was [________________________________], which was accurate at the time it was made.

☐ Even if inaccurate, the misrepresentation was not material because it would not have affected the insurer's decision to issue the policy or set the premium.

☐ The insurer failed to conduct a reasonable investigation before accepting the application and is estopped from raising the misrepresentation.

☐ The contestability period has expired (life/health policies), barring rescission based on misrepresentation.

☐ The misrepresentation must be shown to have been made with intent to deceive (in jurisdictions requiring scienter).

3.5 Coverage Gap / Wrong Policy Type

☐ The correct policy form has been identified and coverage exists under [________________________________].

☐ The agent/broker failed to procure the correct coverage, giving rise to an errors and omissions claim against the agent.

☐ The insured reasonably relied on the agent's representations that the policy provided the coverage at issue.

PART FOUR: BAD FAITH NOTICE

[LAW FIRM LETTERHEAD]

[__/__/____]

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED

[________________________________]
[________________________________]
[________________________________]
[________________________________]

Re: Notice of Bad Faith Claim Handling
Insured: [________________________________]
Policy Number: [________________________________]
Claim Number: [________________________________]
Date of Loss: [__/__/____]

Dear [________________________________]:

This firm represents [________________________________] in connection with the above-referenced claim. We write to place your company on formal notice that its handling of this claim constitutes bad faith in violation of applicable law.

Specific Violations

The following conduct constitutes bad faith and violates applicable unfair claims settlement practices statutes:

☐ Misrepresentation of policy provisions. The denial letter misrepresents the scope of the exclusion at [________________________________] by [________________________________].

☐ Failure to conduct a reasonable investigation. The insurer denied the claim without [________________________________]. A reasonable investigation would have revealed [________________________________].

☐ Failure to affirm or deny coverage within a reasonable time. The claim was reported on [__/__/____] and the insurer did not issue a coverage decision until [__/__/____], a delay of [____] days, which is unreasonable.

☐ Denial without a reasonable basis. The insurer denied coverage despite the fact that liability was reasonably clear because [________________________________].

☐ Failure to provide a reasonable explanation for the denial. The denial letter does not adequately explain the basis for denial or cite specific policy language supporting the denial.

☐ Compelling litigation by offering substantially less than amounts recovered. The insurer offered $[________________________________] despite the documented claim value of $[________________________________].

☐ Failure to adopt and implement reasonable standards for prompt investigation and processing of claims.

☐ Other violations: [________________________________]

Demand for Claim File

Pursuant to applicable law, we demand a complete copy of the entire claim file, including but not limited to:

• All adjuster notes and activity logs
• All internal and external correspondence
• All coverage opinions and legal memoranda (to the extent not privileged)
• All expert reports and estimates
• All recorded statements
• All photographs and documentation
• The complete underwriting file
• All communications between the insurer and any third parties regarding this claim

Available Remedies

Be advised that the Insured's potential remedies for bad faith include, as applicable under the law of the relevant jurisdiction:

• Compensatory damages for all losses caused by the bad faith conduct
• Consequential damages
• Emotional distress damages
• Punitive or exemplary damages
• Statutory penalties (including multiple damages in certain states)
• Attorney fees and costs
• Pre-judgment and post-judgment interest
• Regulatory penalties

Demand

We demand that you immediately:

1. Reverse the denial and pay the claim in full within [____] days;
2. Provide a complete copy of the claim file within [____] days;
3. Identify the individuals involved in the coverage decision-making process.

Failure to respond satisfactorily will result in the filing of a bad faith action and a complaint with the state department of insurance.

Respectfully,

[________________________________]
[________________________________]
[________________________________]

PART FIVE: REGULATORY COMPLAINT LETTER

[DATE: __/__/____]

[State] Department of Insurance
[________________________________]
[________________________________]
[________________________________]

Re: Complaint Against [________________________________]
Insured: [________________________________]
Policy Number: [________________________________]
Claim Number: [________________________________]

Dear Commissioner / Director:

I am writing to file a formal complaint against [________________________________] ("Insurer") regarding its handling of the above-referenced claim. The facts supporting this complaint are as follows:

Background

1. The Insured holds Policy No. [________________________________], a [________________________________] policy issued by the Insurer with effective dates of [__/__/____] to [__/__/____].

2. On [__/__/____], the Insured suffered a loss consisting of [________________________________].

3. The Insured reported the claim on [__/__/____].

4. On [__/__/____], the Insurer denied the claim, citing [________________________________].

Regulatory Violations

The Insurer's conduct violates the following provisions of the state unfair claims settlement practices act:

☐ Misrepresentation of policy provisions (Section [____])
☐ Failure to acknowledge and act promptly on communications (Section [____])
☐ Failure to adopt reasonable standards for prompt investigation (Section [____])
☐ Refusal to pay claims without reasonable investigation (Section [____])
☐ Failure to affirm or deny coverage within a reasonable time (Section [____])
☐ Failure to effectuate prompt, fair, and equitable settlements when liability is reasonably clear (Section [____])
☐ Compelling insureds to litigate by offering substantially less than amounts recovered (Section [____])
☐ Other: [________________________________]

Requested Relief

I respectfully request that the Department:

1. Investigate the Insurer's handling of this claim;
2. Require the Insurer to re-evaluate and pay the claim;
3. Take any enforcement action the Department deems appropriate;
4. Advise me of the Department's findings.

Enclosed Documents

☐ Copy of insurance policy
☐ Copy of denial letter
☐ Copy of response to denial
☐ All correspondence with insurer
☐ Supporting documentation (estimates, reports, photos)
☐ Proof of loss submission
☐ Other: [________________________________]

Respectfully submitted,

[________________________________]
[________________________________]
[________________________________]
[________________________________]

PART SIX: DEMAND FOR RECONSIDERATION WITH SUPPLEMENTAL DOCUMENTATION

[LAW FIRM LETTERHEAD]

[__/__/____]

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED

[________________________________]
[________________________________]

Re: Demand for Reconsideration — Supplemental Documentation
Insured: [________________________________]
Policy Number: [________________________________]
Claim Number: [________________________________]

Dear [________________________________]:

We write on behalf of [________________________________] to demand reconsideration of your denial dated [__/__/____]. In support of this demand, we submit the following supplemental documentation that was not previously available or was not considered in your initial coverage review:

Supplemental Documentation Enclosed

☐ Independent expert report from [________________________________], dated [__/__/____], which concludes that [________________________________]. (Exhibit [____])

☐ Contractor/repair estimate from [________________________________] in the amount of $[________________________________], confirming the scope and cost of [________________________________]. (Exhibit [____])

☐ Engineering report from [________________________________], which confirms that [________________________________]. (Exhibit [____])

☐ Medical records/reports from [________________________________], documenting [________________________________]. (Exhibit [____])

☐ Witness statement(s) from [________________________________], establishing that [________________________________]. (Exhibit [____])

☐ Photographs/video taken on [__/__/____], showing [________________________________]. (Exhibit [____])

☐ Public records including [________________________________], which demonstrate [________________________________]. (Exhibit [____])

☐ Other documentation: [________________________________] (Exhibit [____])

How This Documentation Addresses the Denial

This supplemental evidence directly refutes the stated basis for denial as follows:

1. As to [denial basis 1]: [________________________________]
2. As to [denial basis 2]: [________________________________]
3. As to [denial basis 3]: [________________________________]

Demand

We demand that you:

1. Review this supplemental documentation within [____] days;
2. Reverse the denial and pay the claim in the amount of $[________________________________];
3. Provide a written response to each item of supplemental evidence submitted.

If the denial is not reversed within [____] days of receipt of this letter, we will proceed with all available legal and regulatory remedies.

Respectfully,

[________________________________]
[________________________________]

Enclosures: As described above

PART SEVEN: LITIGATION PRE-FILING CHECKLIST

Before filing suit against the insurer, confirm the following:

7.1 Exhaustion of Pre-Suit Requirements

☐ Denial response letter sent and deadline expired
☐ Bad faith notice sent (where required as a statutory prerequisite)
☐ State-specific statutory notice requirements satisfied:
- ☐ Civil remedy notice filed (FL)
- ☐ 60-day cure period expired (FL)
- ☐ Demand letter sent with required content (state-specific)
☐ Regulatory complaint filed (optional but recommended)
☐ Internal appeal/reconsideration exhausted (if applicable)

7.2 Statute of Limitations Analysis

☐ Breach of contract statute of limitations: [____] years from [________________________________]
☐ Bad faith tort statute of limitations: [____] years from [________________________________]
☐ Statutory claim limitations period: [____] years from [________________________________]
☐ Discovery rule applicability: [________________________________]
☐ Tolling arguments available: [________________________________]

7.3 Document Preservation and Collection

☐ All policy documents (declarations, forms, endorsements, applications)
☐ Complete denial letter and all correspondence
☐ All response letters sent to insurer
☐ Proof of loss and all supporting documentation
☐ All estimates, reports, and expert opinions
☐ Photographs and video of the loss
☐ Complete timeline of events
☐ Phone logs and email records with insurer
☐ Agent/broker communications
☐ Prior claim history
☐ Premium payment records
☐ Testimony / witness statements
☐ Social media posts referencing the loss (preserve and review)

7.4 Damages Documentation

☐ Contract damages: amount of unpaid claim ($[________________________________])
☐ Consequential damages: [________________________________]
☐ Out-of-pocket expenses caused by denial: [________________________________]
☐ Lost income / business interruption: [________________________________]
☐ Emotional distress damages: [________________________________]
☐ Attorney fees incurred to obtain coverage: $[________________________________]
☐ Interest calculations: [________________________________]
☐ Punitive damages evidence (insurer conduct, financial condition): [________________________________]

7.5 Cause of Action Checklist

☐ Breach of insurance contract
☐ Breach of implied covenant of good faith and fair dealing (common law bad faith)
☐ Statutory bad faith (state-specific)
☐ Violation of unfair claims settlement practices act (if private right of action exists)
☐ Violation of state consumer protection / deceptive trade practices act
☐ Declaratory judgment (coverage determination)
☐ Fraud / misrepresentation by insurer
☐ Tortious breach of contract (where recognized)
☐ Negligent claims handling (where recognized)

7.6 Venue and Jurisdiction Analysis

☐ State court vs. federal court (diversity jurisdiction threshold: $75,000)
☐ Removal risk assessment
☐ Applicable forum selection clauses
☐ Venue selection considerations
☐ Choice of law analysis

PART EIGHT: GENERAL PRACTICE NOTES

8.1 Policy Interpretation Principles

The following rules of policy interpretation apply in virtually all jurisdictions:

1. Plain meaning rule: Policy language is given its plain and ordinary meaning.
2. Ambiguity construed against insurer: Where policy language is ambiguous (susceptible to two or more reasonable interpretations), it is construed against the insurer as drafter (contra proferentem).
3. Reasonable expectations: Coverage is interpreted in accordance with the objectively reasonable expectations of the insured.
4. Broad construction of insuring agreements: The insuring agreement is construed broadly to afford coverage.
5. Narrow construction of exclusions: Exclusions are strictly construed against the insurer.
6. Burden of proof:
   - The insured bears the burden of establishing coverage under the insuring agreement.
   - The insurer bears the burden of establishing the applicability of an exclusion.
   - The insured bears the burden of establishing an exception to an exclusion.

8.2 Key Deadlines Tracking

8.3 Communication Best Practices

☐ Always communicate with the insurer in writing (certified mail and email)
☐ Maintain a detailed log of all telephone communications (date, time, participants, substance)
☐ Never accept verbal assurances of coverage without written confirmation
☐ Request all coverage decisions in writing
☐ Keep copies of everything sent to and received from the insurer
☐ Calendar all deadlines
☐ Send correspondence via certified mail, return receipt requested, to establish proof of delivery

8.4 NAIC Model Act Background

The NAIC Unfair Claims Settlement Practices Act (Model #900) provides the framework adopted in some form by most states. Key prohibited practices include:

1. Misrepresenting pertinent facts or policy provisions relating to coverages at issue
2. Failing to acknowledge and act reasonably promptly upon communications with respect to claims
3. Failing to adopt and implement reasonable standards for prompt investigation
4. Refusing to pay claims without conducting a reasonable investigation
5. Failing to affirm or deny coverage within a reasonable time after proof of loss
6. Not attempting in good faith to effectuate prompt, fair, and equitable settlement when liability is reasonably clear
7. Compelling insureds to institute litigation to recover amounts due by offering substantially less than amounts ultimately recovered
8. Attempting to settle claims on altered applications without the insured's knowledge or consent
9. Making claims payments without providing a statement of coverage
10. Making known appeals of arbitration awards as a practice to compel claimants to accept less than the award amount

Important: In many states, the UCSPA does not create a private right of action and is enforced only by the state insurance department. Some states have enacted separate statutes providing private remedies. Always check the applicable state law.

SOURCES AND REFERENCES

• NAIC Model Unfair Claims Settlement Practices Act (Model #900): https://content.naic.org/
• Couch on Insurance (treatise on insurance policy interpretation)
• Appleman on Insurance Law and Practice
• IRMI (International Risk Management Institute): https://www.irmi.com/
• State Department of Insurance websites (see state-specific templates)
• United Policyholders (nonprofit policyholder advocacy): https://uphelp.org/

This template is provided for informational purposes only and does not constitute legal advice. It must be reviewed and customized by a qualified attorney licensed in the relevant jurisdiction before use. Insurance law varies significantly by state, and this template should be used in conjunction with the applicable state-specific version.

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