Free Proposed Jury Instructions - District Court of Arizona - Arizona

Claims and Defenses To help you follow the evidence, I will give you a brief summary of the positions of the parties: The Plaintiff claims that Defendant breached the insurance contract by refusing to pay portions of his claims concerning loss of use and costs of replacing or repairing his fire damages. Plaintiff further claims that Defendant refused to pay his claims either knowing of, or with reckless disregard of, the absence of any reasonable basis for such refusal. State Farm denies these claims.

SOURCE: Ninth Circuit Model Civil Jury Instruction 1.2 (modified)

Case 2:03-cv-01415-ROS

Document 142-3

Filed 11/29/2005

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