IN THIS ISSUE:

- Texas Court of Appeals: Trial Court Must Sever Breach of Contract and Bad Faith Claims Following an Insurer’s Offer to Settle pages 1 - 2

- Third District Court of Appeals of Florida Holds that Discovery of Insurer’s Business Practices is Premature Before Determination of Coverage page 2

- The Third Circuit Finds Insurer had Reasonable Basis for Denial of Claim where Adjuster Reviewed Claim, Outside Counsel Provided Coverage Opinion, and Insurer Reconsidered Denial pages 3 - 4

- According To An Arizona Court, Bifurcation Of Breach of Contract And Bad Faith Claims Is Not Warranted Where Resolution of Contract Claim Would Not Necessarily Impact Outcome Of Bad Faith Claim pages 4 - 5

- Montana Court Determines That Claim Preclusion Bars Plaintiff From Filing Common- Law Bad Faith Action After Dismissal Of Lawsuit Alleging Statutory Unfair Trade Practices Claim pages 5 - 6