HOWARD et al v. ACE AMERICAN INSURANCE COMPANY et al

"27. On information and belief, ESIS is a wholly owned subsidiary of ACE. On further information and belief, ESIS provides risk management services to ACE, including handling of claims for workers compensation cases.
28. On information and belief, Gail's claim arose under the Defense Base Act, but the provisions of the LHWCA apply to processing her claim for medical and compensation benefits due to her injury on Midway.
29. ACE, through ESIS, was initially notified of Mrs. Howard's accident on August 15,2005.
30. In a report dated August 15, 2005, submitted by Chugach ESIS. Chugach indicated it did not question the claim.
43. On September 8, 2006, the OWCP sent another letter to ACE, requesting submission of form LS-206, Payment of Compensation Without Award, and seeking additional medical records for Gail. ACE never responded.
44. In a follow-up letter dated April 27, 2007, the OWCP asked ACE to provide the amount and dates during which compensation had been paid.
45. ACE had paid nothing in compensation benefits. The OWCP also requested all medical reports not previously requested, a status update on the injury, and the claimant's current mailing address. ACE failed to respond.
46. The OWCP sent a fourth letter to ACE on May 13, 2008, denoted in bold print as the "THIRD REQUEST." The letter stated,
Please advise amount and inclusive dates for which compensation has been paid and submit a copy of any medical reports not previously submitted . ... No response was received to our requests on 04/17107 and 09/08/06.
51. Therefore, for four years, ACE inexcusably ignored repeated requests to provide Gail's address so that OWCP could finally communicate with and advise Gail of her rights to compensation.
52. ACE also refused to provide to the OWCP requested information regarding the amount of compensation it had paid Gail, knowing it had failed to pay any compensation."