The court held that where the insured did not offer a valid basis for lay witness testimony under Rule 701, a witness was precluded from offering testimony relying on technical or specialized knowledge, and also granted the insurer's motion to strike an expert's report where the insured did not timely disclose the expert or offer a valid basis for admitting his report, and the court further denied the insurer's motion for summary judgment with respect to breach of contract because there was a genuine dispute of material fact as to coverage and damages, but granted the motion with respect to bad faith because no reasonable jury could conclude that the insurer lacked any basis for its assessment.
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