Insurance Bad Faith Demand Letter - Maine

INSURANCE BAD FAITH DEMAND LETTER

State of Maine

[LAW FIRM LETTERHEAD]

PRIVILEGED AND CONFIDENTIAL
SETTLEMENT COMMUNICATION — FOR RESOLUTION PURPOSES ONLY
PROTECTED UNDER MAINE RULES OF EVIDENCE RULE 408 AND F.R.E. 408

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND VIA EMAIL TO: [________________________________]

Date: [__/__/____]

[INSURANCE COMPANY NAME]
[________________________________]
[________________________________]
[City], [State] [Zip]

Attention: [________________________________], [________________________________]
Re: FORMAL DEMAND — BAD FAITH / BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING — MAINE LAW
Insured: [________________________________]
Claimant: [________________________________]
Policy Number: [________________________________]
Claim Number: [________________________________]
Date of Loss: [__/__/____]
Policy Limits: $[________________________________]
Response Deadline: [__/__/____] at 5:00 p.m. Eastern Time

Dear [________________________________]:

I. INTRODUCTION AND NATURE OF DEMAND

This firm represents [________________________________] ("our client") in connection with the above-referenced insurance claim. This letter constitutes a formal demand for payment of policy benefits wrongfully withheld and serves as notice of [________________________________] (the "Company" or "[CARRIER SHORT NAME]") breach of its implied covenant of good faith and fair dealing under Maine law, as well as violations of Maine's Unfair Claims Settlement Practices statute, the Maine Unfair Trade Practices Act, and the Company's express contractual obligations.

This is a time-limited demand. The Company has until [__/__/____] to tender the full amount of $[________________________________] and resolve all claims arising from this loss. Failure to do so will result in litigation seeking all available remedies, including consequential damages, statutory interest at 1.5% per month, attorney fees, and such punitive damages as the evidence may support.

II. MAINE BAD FAITH LAW — GOVERNING FRAMEWORK

Maine's framework for insurer misconduct is distinct from many states and must be understood precisely to assess the Company's exposure in this matter.

A. Implied Covenant of Good Faith and Fair Dealing

Maine law recognizes that every insurance contract includes an implied covenant of good faith and fair dealing. Marquis v. Farm Family Mut. Ins. Co., 628 A.2d 644, 648 (Me. 1993). This duty exists regardless of whether the claim involves a first-party or third-party context, and it arises at the time the parties enter the contract — not merely when a claim is made. Id. The rationale for imposing this duty on insurers is "equally applicable and of equal importance when the insured seeks payment of legitimate damages from his own insurance company." Id. (quoting Anderson v. Continental Ins. Co., 271 N.W.2d 368, 375 (Wis. 1978)).

In third-party contexts, the Company's duty of good faith requires it to give equal weight to the insured's interests as to its own when evaluating settlement demands within policy limits. Linscott v. State Farm Mut. Auto. Ins. Co., 368 A.2d 1161, 1163 (Me. 1977).

B. No Independent Bad Faith Tort — But Broad Consequential Damages

Maine does not recognize an independent tort of bad faith as a separate cause of action from breach of contract. Marquis, 628 A.2d at 652. However, the Supreme Judicial Court of Maine has explicitly held that the insured's remedies for breach of the implied covenant are not limited to the face value of the policy. An insured who proves breach may recover the full consequential damages proximately caused by the insurer's breach — including lost profits, consequential financial harm, and other out-of-pocket damages flowing from the insurer's failure to fulfill its contractual obligations.

The Marquis benchmark: In Marquis, the jury awarded $680,000 in consequential damages — primarily lost profits — on two policies with combined limits of only $77,000. The Maine Supreme Judicial Court affirmed. The Company's exposure in the present case is not limited by the policy limits if its breach has caused consequential harm.

C. Emotional Distress and Punitive Damages — What Is Required

Maine limits emotional distress damages in insurance contract actions. Because insurance contracts are not among the "special" contract types that warrant emotional distress damages absent physical injury, emotional distress damages are generally not available in a contract-only bad faith action. Marquis, 628 A.2d at 651; Colford v. Chubb Life Ins. Co., 687 A.2d 609, 616 (Me. 1996).

However, to recover emotional distress damages and punitive damages, an insured must demonstrate that the insurer committed independently tortious conduct beyond the mere denial of the claim. Colford, 687 A.2d at 616. In the present matter, the Company's conduct — as set forth below — constitutes independently tortious conduct sufficient to support such damages.

D. Punitive Damages Standard — Maine Law

Under Maine law, punitive damages are available where the defendant's conduct was motivated by actual malice — specifically, ill will directed at the plaintiff — or where the conduct was so outrageous that malice may be implied. Tuttle v. Raymond, 494 A.2d 1353, 1360–64 (Me. 1985). Punitive damages must be established by clear and convincing evidence. Id. There is no statutory cap on punitive damages in Maine; courts apply constitutional proportionality principles. See 14 M.R.S.A. § 1602-B.

The Company's conduct in this matter rises to the level required for punitive damages because [DESCRIBE SPECIFIC AGGRAVATING CONDUCT].

E. Private Civil Action — 24-A M.R.S.A. § 2436-A

In addition to contract remedies, Maine's Unfair Claims Settlement Practices statute, 24-A M.R.S.A. § 2436-A, provides a private civil right of action for the following specific violations:

• (A) Knowingly misrepresenting to an insured pertinent facts or policy provisions relating to coverage at issue
• (B) Failing to acknowledge and review claims within a reasonable time following receipt of written notice
• (C) Threatening to appeal an arbitration award for the sole purpose of compelling acceptance of a lesser settlement
• (D) Failing to affirm or deny coverage, reserving appropriate defenses, within a reasonable time after completing its investigation
• (E) Without just cause, failing to effectuate a prompt, fair, and equitable settlement where liability has become reasonably clear

Remedies under § 2436-A: Damages, costs and disbursements, reasonable attorney fees, and interest at 1.5% per month on damages. 24-A M.R.S.A. § 2436-A(1).

"Without just cause" means refusing to settle without a reasonable basis to contest liability, the amount of damages, or the extent of injuries. 24-A M.R.S.A. § 2436-A(2).

Important distinction: 24-A M.R.S.A. § 2164-D (the regulatory unfair claims practices statute) does not create a private cause of action — only the Superintendent may enforce that provision. § 2164-D(8). The private action is under § 2436-A.

F. Maine Unfair Trade Practices Act — 5 M.R.S.A. § 207

Under 5 M.R.S.A. § 207, unfair or deceptive acts in the conduct of any trade or commerce — expressly including insurance — are unlawful. A policyholder who suffers a loss of money or property as a result may maintain a private action under 5 M.R.S.A. § 213 for actual damages, costs, and attorney fees. Curtis v. Allstate Ins. Co., 2002 ME 9, ¶ 38, 787 A.2d 760 (signing a release does not qualify as loss of money or property; actual underpayment or financial harm does).

G. Overdue Payment Statute — 24-A M.R.S.A. § 2436

Undisputed claims must be paid within 30 days of proof of loss (or 60 days for fire policy claims). Overdue undisputed amounts bear interest at 1.5% per month, and the insurer must pay reasonable attorney fees if overdue benefits are recovered in litigation or paid after notice of attorney representation. 24-A M.R.S.A. § 2436(3)–(4).

III. POLICY INFORMATION AND COVERAGE

A. Policy Details

B. Coverage Established

The policy provides coverage for [________________________________]. The loss clearly falls within the policy's insuring agreement, and coverage has been [ACKNOWLEDGED BY THE COMPANY / IS UNDENIABLE UNDER THE FACTS AND POLICY LANGUAGE] for the following reasons:

1. The covered peril or trigger is [________________________________]
2. The policy was in force on the date of loss
3. The covered property / insured person is [________________________________]
4. No exclusion applies because [________________________________]

The Company is obligated under Maine law to:

☐ Conduct a thorough, fair, objective, and timely investigation
☐ Evaluate the claim based on full and accurate information
☐ Promptly pay all amounts owed under the policy
☐ Communicate honestly and transparently with its insured
☐ Avoid unreasonable delays in claim handling
☐ Not compel litigation through unreasonable refusal or delay
☐ Give equal consideration to the insured's interests alongside its own

IV. FACTUAL BACKGROUND AND BAD FAITH CHRONOLOGY

A. The Underlying Loss

On [__/__/____], [________________________________].

[DETAILED DESCRIPTION OF THE LOSS OR CLAIM EVENT]

Our client timely reported the claim to the Company on [__/__/____]. From that point forward, the Company has engaged in a pattern of conduct that constitutes breach of its duty of good faith and fair dealing, specific violations of 24-A M.R.S.A. § 2436-A, and, as detailed below, independently tortious conduct justifying emotional distress and punitive damages.

B. Chronological Timeline of Bad Faith Conduct

The following timeline documents the Company's misconduct:

V. SPECIFIC BAD FAITH CONDUCT

The following specific conduct by [CARRIER SHORT NAME] constitutes breach of the implied covenant of good faith and fair dealing under Marquis and, in certain respects, independently tortious conduct justifying additional remedies under Colford:

A. Bad Faith Investigation

[CARRIER SHORT NAME] conducted its investigation of this claim in bad faith — mirroring the conduct condemned in Marquis. Specifically:

☐ The Company failed to interview [________________________________], whose statements directly support our client's position
☐ The Company withheld from its own experts the fact that [________________________________]
☐ The Company selectively relied on [________________________________] while ignoring [________________________________]
☐ The Company's investigator, [________________________________], failed to [________________________________]
☐ The Company's examination under oath / recorded statement was used not to investigate but to [________________________________]
☐ [________________________________]

In Marquis, the Court affirmed a bad faith finding where the insurer's investigator failed to interview witnesses with exculpatory information and withheld a prior claim from the fire investigator. The conduct here is directly analogous.

B. Unreasonable Delay

The Company has unreasonably delayed the investigation, evaluation, and payment of this claim in violation of its contractual obligations and Maine law:

☐ [____] days elapsed between claim submission ([__/__/____]) and the Company's first substantive response ([__/__/____]) — far exceeding reasonable standards and the § 2436 / § 2436-A deadlines
☐ The Company requested duplicative information — proof of loss and subsequent verification producing no new data — in violation of 24-A M.R.S.A. § 2164-D(3)(I)
☐ The Company failed to provide required claim forms within 15 calendar days of request — 24-A M.R.S.A. § 2164-D(3)(K)
☐ [________________________________]
☐ [________________________________]

As a direct consequence of this unreasonable delay, our client has suffered:

• [________________________________] (describe financial harm)
• [________________________________] (describe additional damages caused by the delay itself)

C. Misrepresentation of Policy Provisions and Facts — § 2436-A(A)

[CARRIER SHORT NAME] has knowingly misrepresented pertinent facts and policy provisions, triggering the private cause of action under § 2436-A(A):

☐ The Company represented that [________________________________] was excluded under [policy provision], when in fact [________________________________]
☐ The Company represented that our client's claim was worth only $[________________], knowingly understating the damages by [________________________________]
☐ The Company represented that our client was required to [________________________________], a requirement not found in the policy
☐ [________________________________]

D. Failure to Acknowledge and Review Claim — § 2436-A(B)

The Company failed to acknowledge and review this claim within a reasonable time following receipt of written notice. The claim was submitted on [__/__/____]. The Company did not provide a substantive acknowledgment until [__/__/____], a delay of [____] days. Under the circumstances of this claim, a reasonable time for acknowledgment and initial review was [____] days.

E. Failure to Affirm or Deny Coverage — § 2436-A(D)

The Company completed its investigation on approximately [__/__/____] — as evidenced by [________________________________] — but failed to affirm or deny coverage, reserving appropriate defenses, until [__/__/____], a delay of [____] additional days without justification. This violates § 2436-A(D).

F. Failure to Settle Where Liability Is Clear — § 2436-A(E)

Liability under this policy became reasonably clear no later than [__/__/____], when [________________________________]. Since that date, the Company has failed without just cause to effectuate a prompt, fair, and equitable settlement. The Company's only offers to date have been:

Under § 2436-A(2), the Company acts "without just cause" when it refuses to settle without a reasonable basis to contest liability, the amount of damages, or the extent of injuries. The Company has no reasonable basis for its current position because [________________________________].

G. Compelling Litigation Through Unreasonable Conduct

The Company's unreasonable refusal to pay benefits clearly owed has compelled our client to retain legal counsel and, if this demand is rejected, will compel litigation. This conduct is a hallmark of bad faith claims handling and is expressly prohibited by 24-A M.R.S.A. § 2164-D(3). The costs our client has incurred and will incur — including attorney fees, expert costs, and litigation expenses — are directly attributable to the Company's breach.

H. Independently Tortious Conduct (Supporting Emotional Distress and Punitive Damages)

Under Colford v. Chubb Life Ins. Co., 687 A.2d 609, 616 (Me. 1996), emotional distress and punitive damages require proof of "independently tortious conduct beyond the denial of the claim." The Company's conduct here satisfies this standard because:

☐ The Company's investigator made false statements to our client, specifically [________________________________]
☐ The Company engaged in [________________________________], which constitutes [fraud / intentional misrepresentation / negligent misrepresentation]
☐ The Company's agent [________________________________] made defamatory statements about our client to [________________________________]
☐ The Company intentionally [________________________________] with knowledge that it would cause harm to our client
☐ [________________________________]

This conduct gives rise to claims for emotional distress damages and punitive damages under Maine law.

VI. STATUTORY VIOLATIONS — ITEMIZED

A. 24-A M.R.S.A. § 2436 — Overdue Payment

☐ The Company failed to pay the undisputed portion of the claim within 30 days (or 60 days for fire claims) after proof of loss — § 2436(1)
☐ The Company failed to provide a written dispute notice with sufficient grounds and detail — § 2436(2)
☐ Statutory interest at 1.5% per month has been accruing since [__/__/____] on the overdue amount of $[________________________________]
☐ Accrued interest through [__/__/____]: $[________________________________]

B. 24-A M.R.S.A. § 2436-A — Unfair Claims Settlement Practices (Private Action)

The Company has committed the following specific violations giving rise to a private cause of action:

☐ (A) Knowingly misrepresenting pertinent facts or policy provisions — [DESCRIBE]
☐ (B) Failing to acknowledge and review the claim within a reasonable time — [DESCRIBE TIMELINE]
☐ (D) Failing to affirm or deny coverage within a reasonable time after completing investigation — [DESCRIBE TIMELINE]
☐ (E) Without just cause, failing to effectuate a prompt, fair, and equitable settlement — [DESCRIBE]

C. 24-A M.R.S.A. § 2164-D — Regulatory Violations (MBI Enforcement)

The Company's conduct constitutes unfair claims practices under § 2164-D subject to MBI regulatory action, including the following:

☐ (3)(A) Knowingly misrepresenting relevant facts or policy provisions to claimants
☐ (3)(B) Failing to acknowledge pertinent written communications with reasonable promptness
☐ (3)(C) Failing to adopt and implement reasonable standards for prompt investigation and settlement
☐ (3)(D) Failing to develop and maintain documented claim files supporting decisions
☐ (3)(E) Refusing to pay claims without conducting a reasonable investigation
☐ (3)(F) Failing to affirm or deny coverage within a reasonable time
☐ (3)(I) Unreasonably delaying investigation or payment
☐ (3)(J) Failing to promptly provide an accurate written explanation for denial or compromise offer
☐ (3)(K) Failing to provide claim forms within 15 calendar days of request
☐ (5) Failing to deal in good faith with the insured to resolve claims — general business practice

D. 5 M.R.S.A. § 207 — Maine Unfair Trade Practices Act

The Company's misrepresentations, deceptive claims handling, and compulsion of litigation to recover undisputed benefits constitutes unfair and deceptive conduct in the conduct of trade under 5 M.R.S.A. § 207. Our client has suffered actual financial loss — specifically, underpayment of $[________________________________] and consequential expenses of $[________________________________] — giving rise to a private action under 5 M.R.S.A. § 213.

VII. DAMAGES

A. Contract / Policy Benefits

B. Consequential Damages for Breach of Covenant of Good Faith

Under Marquis, 628 A.2d at 650–51, consequential damages proximately caused by the insurer's breach of the implied covenant are fully recoverable. Our client has suffered the following consequential damages as a direct result of the Company's breach:

C. Statutory Interest — 24-A M.R.S.A. § 2436(3)

Overdue Amount: $[________________________________]
Interest Rate: 1.5% per month
Accrual Start Date: [__/__/____]
Accrued Interest through [__/__/____]: $[________________________________]
Continuing at $[____] per day until paid

D. Attorney Fees — 24-A M.R.S.A. § 2436(4) and § 2436-A(1)

Our client is entitled to recovery of reasonable attorney fees under both 24-A M.R.S.A. § 2436(4) (overdue payment) and § 2436-A(1) (unfair claims settlement practices violations). Estimated attorney fees through trial: $[________________________________].

E. Emotional Distress Damages

[IF INDEPENDENTLY TORTIOUS CONDUCT IS ALLEGED: Per Colford, 687 A.2d at 616, emotional distress damages are recoverable where the insurer has committed independently tortious conduct beyond the denial of the claim. As set forth in Section V.H above, the Company's conduct satisfies this standard. Our client has suffered severe emotional distress, including [DESCRIBE: anxiety, depression, insomnia, physical manifestations, medical treatment for emotional distress]. Emotional distress damages claimed: $[________________________________].]

[IF NOT APPLICABLE: Emotional distress damages are not claimed in this matter, as our client's primary remedies are contract and statutory.]

F. Punitive Damages

Under Tuttle v. Raymond, 494 A.2d 1353, 1360–64 (Me. 1985), punitive damages require proof of malice by clear and convincing evidence. The Company's conduct — specifically [________________________________] — constitutes actual malice toward our client [OR: conduct so outrageous that malice may be implied]. There is no statutory cap on punitive damages in Maine, though courts apply constitutional proportionality. 14 M.R.S.A. § 1602-B.

Punitive damages will be sought at trial in an amount sufficient to punish the Company for its conduct and deter similar conduct in the future.

G. Demand Summary

Note: Punitive damages are not included in this settlement figure. Our client reserves the right to seek punitive damages at trial.

VIII. FORMAL DEMAND

Based on the foregoing, we hereby demand that [CARRIER SHORT NAME]:

A. Monetary Payment

Tender the sum of $[________________________________] in certified funds or wire transfer, on or before [__/__/____], as full compensation for policy benefits, consequential damages, accrued statutory interest, and attorney fees as itemized above.

B. Additional Non-Monetary Terms

☐ Provide a complete written explanation — citing specific policy provisions — for each item that has been denied or reduced
☐ Certify in writing that no adverse information regarding this claim has been submitted to CLUE, ISO ClaimSearch, or any other insurance industry database that could affect our client's insurability
☐ Execute a complete release of all claims by the Company against our client arising from this loss
☐ [________________________________]

IX. TIME-LIMITED NATURE OF THIS DEMAND

THIS DEMAND EXPIRES AT 5:00 P.M. EASTERN TIME ON [__/__/____].

This is a time-limited demand. If [CARRIER SHORT NAME] fails to unconditionally accept this demand by the stated deadline:

1. Litigation will be filed immediately in the Superior Court of [________________________________] County, Maine, seeking all available remedies including:
   - Full policy benefits with prejudgment interest
   - All consequential damages proximately caused by the Company's breach — Marquis, 628 A.2d 644
   - Statutory interest at 1.5% per month — 24-A M.R.S.A. § 2436(3)
   - Reasonable attorney fees — 24-A M.R.S.A. § 2436(4) and § 2436-A(1)
   - § 2436-A damages and fees for all enumerated violations
   - UTPA damages and fees — 5 M.R.S.A. §§ 207 & 213
   - Emotional distress damages (where independently tortious conduct is shown)
   - Punitive damages without limitation — Tuttle v. Raymond

2. This demand will be withdrawn as a settlement offer, and our client will seek all available damages without limitation.

3. Regulatory complaints will be filed with:
   - Maine Bureau of Insurance (MBI), 34 State House Station, Augusta, ME 04333-0034, Tel: (207) 624-8475
   - National Association of Insurance Commissioners (NAIC) Consumer Information Source

4. Media and public disclosure of the Company's claims practices may be pursued to the extent permitted by law and professional conduct rules.

X. DOCUMENT PRESERVATION NOTICE — LITIGATION HOLD

This letter constitutes formal notice to [CARRIER SHORT NAME] and all of its officers, directors, employees, agents, and outside counsel to immediately preserve all documents, electronically stored information (ESI), and tangible evidence relating to this claim or our client, including but not limited to:

• The complete claim file in all versions, including all prior drafts, handwritten notes, and electronic records
• All adjuster notes, field diaries, telephone logs, and activity logs
• All internal communications (email, voicemail, text messages, instant messages, internal memoranda) regarding this claim or our client
• All reserve information and reserve change documentation, including supervisor approvals
• All expert reports, consultant communications, and evaluations
• All surveillance footage, photographs, or videos of our client or the subject property
• All claims handling guidelines, manuals, best practices documents, and training materials in effect at the time of this claim
• All quality assurance, compliance, or audit reports related to this claim or similar claims
• All communications with reinsurers regarding this claim
• All documents relating to the Company's evaluation of the likelihood of litigation

Destruction, alteration, or concealment of any such materials following receipt of this notice will constitute spoliation of evidence under Maine law, giving rise to adverse inference instructions and such other sanctions as the court may impose.

XI. CONCLUSION

Maine law is unambiguous: every insurance company owes its insureds a duty to act in good faith and deal fairly in the handling of their claims. Marquis v. Farm Family Mut. Ins. Co., 628 A.2d 644 (Me. 1993). When that duty is breached, Maine courts have not hesitated to award consequential damages — as in Marquis, where the judgment exceeded policy limits by nearly ten-fold — and to impose statutory penalties, attorney fees, and interest.

[CARRIER SHORT NAME] stands at a crossroads. It can fulfill its obligations now — by paying what is owed, with the statutory interest and fees that have accrued — or it can force litigation, in which the Company will face not only the policy benefits and consequential damages documented above, but also attorney fees, statutory interest, and the potential for punitive damages where the evidence supports a finding of malice.

We strongly encourage the Company to use this opportunity to resolve this matter fairly, consistent with its obligations under Maine law.

Please direct all communications to the undersigned.

Respectfully submitted,

[LAW FIRM NAME]

By: ___________________________________
[________________________________]
Maine Bar No. [____]
[________________________________]
[________________________________], ME [________]
Tel: [________________________________]
Fax: [________________________________]
Email: [________________________________]

Counsel for [________________________________]

ENCLOSURES:
☐ Policy declarations page and relevant provisions
☐ Claim correspondence chronology
☐ Proof of loss and supporting documentation
☐ Expert reports and damage documentation
☐ Evidence of independently tortious conduct (if applicable)
☐ Documentation of consequential damages
☐ Attorney fee summary

CC:
☐ [________________________________] (Client)
☐ Maine Bureau of Insurance, 34 State House Station, Augusta, ME 04333-0034 (if complaint filed simultaneously)

MAINE BAD FAITH / INSURER MISCONDUCT — QUICK REFERENCE

SOURCES AND REFERENCES

• Marquis v. Farm Family Mut. Ins. Co., 628 A.2d 644 (Me. 1993): https://law.justia.com/cases/maine/supreme-court/1993/628-a-2d-644-0.html
• Colford v. Chubb Life Ins. Co., 687 A.2d 609 (Me. 1996) — emotional distress / punitive damages threshold
• Tuttle v. Raymond, 494 A.2d 1353 (Me. 1985) — punitive damages; malice; clear and convincing evidence
• Linscott v. State Farm Mut. Auto. Ins. Co., 368 A.2d 1161 (Me. 1977) — third-party good faith duty
• Curtis v. Allstate Ins. Co., 2002 ME 9, 787 A.2d 760 — UTPA / loss of money requirement
• Chiapetta v. Lumbermens Mut. Ins. Co., 583 A.2d 198 (Me. 1990) — good faith; fire claim procedures
• Maine Legislature — 24-A M.R.S.A. § 2436-A: https://legislature.maine.gov/statutes/24-a/title24-Asec2436-A.html
• Maine Legislature — 24-A M.R.S.A. § 2436: https://legislature.maine.gov/statutes/24-a/title24-Asec2436.html
• Maine Legislature — 24-A M.R.S.A. § 2164-D: https://www.mainelegislature.org/legis/statutes/24-a/title24-Asec2164-D.html
• Maine Legislature — 5 M.R.S.A. § 207: https://www.mainelegislature.org/legis/statutes/5/title5sec207.html
• Maine Legislature — 14 M.R.S.A. § 752: https://www.mainelegislature.org/legis/statutes/14/title14ch205.pdf
• ALFA International Maine Insurance Law Compendium: https://www.alfainternational.com/compendium/insurance-law/maine/
• United Policyholders — Insurance Consumer Rights in Maine: https://uphelp.org/claim-guidance-publications/insurance-consumer-rights-in-maine-2022/
• Maine Bureau of Insurance: https://www.maine.gov/pfr/insurance