A claim of Bad Faith in settlement under a First-Party auto coverage does not survive without supporting Affidavits or Expert Testimony or other Proof in Sehmann v. General Casualty Insurance Cos., 2006 WL 2883273 (Ct. App. Wis. Case No. 2005AP2108 Opinion Filed October 12, 2006) (subscription required), Public Access Site Provided by Court of Appeals of Wisconsin.
The Court of Appeals of Wisconsin left no doubt about their holding: "The defendant's [the insurance company's] affidavits show a reasonable process was used to arrive at its offers. Cichowski [plaintiff-appellant] did not submit any affidavits as to what a more proper evaluation would have been, nor any expert opinions describing what process the defendant should have used instead. Summary judgment was properly granted to General Casualty on this claim." (Paragraph 10.)
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