ALLGEIER v. ACE AMERICAN INSURANCE COMPANY

"12. On or about December 8, 2006 at or near 205 Liverton Court, Louisville, Jefferson County, Kentucky 40222, an employee-driver of MV, acting within the course and scope of her employment, assisted Ms. Allgeier's unloading and exit from an MV paratransit bus in a careless, reckless, willful, wanton, negligent and/or grossly negligent manner and in violation of MV company policies (hereinafter referred to as the "incident").

13. THe incident caused severe injuries to Ms. Allgeier.
14. MV was clearly liable for Ms. Allgeier's injuries, yet, it made no meaningful attempt to investigate the incident...
...20. Defendant ACE was or-with a reasonable, timely, and unbiased investigation- would have been aware of the extent of Ms. Allgeier's inuries and MV's liability for several years before any effort was made to settle Ms. Allgeier's claim.
21. On numerous occasions well before trial, ACE was given due and timely notice of the breadth of Ms. allgeier's liability claim against its insured, MV, arising out of the incident...
...24. In fact, ACE made no effort to settle Ms. Allgeier's claims against its insured until shortly before trial, nearly four years after the incident."