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DOCKET NO.: MMX-CV19-6023735-S : SUPERIOR COURT
ANN L. GILLESPIE-WHITE J.D. OF MIDDLESEX
V. : AT MIDDLETOWN
GOVERNMENT EMPLOYEES INSURANCE CO.: DECMEBER 11, 2022
AMENDED PLAINTIFF’S DISCLOSURE OF EXPERT WITNESS
Pursuant to Practice Book Sections 13-4, 13-4(a) and 13-15, the plaintiff hereby amends her
disclosure that she may call the following expert witness at the time of trial:
I. Identity of Expert Witness:
Peter Knowe of Knowe Consulting, LLC, 2012 Wilmington Place, Birmingham, Alabama,
35242.
II. Field of Expertise and Subject Matter.
Insurance claims adjusting and insurance claims management including the investigation of
coverage, liability, causation and damages, the valuation of claims, the resolution of claims,
and the interactions and communications with insureds and claimants all as required by the
insurance policy, industry standards, industry organization standards, insurance carrier
internal standards, as well as state standards by statute and/or regulation, state regulator
standards, and the National Association of Insurance Commissioners standards.
III. The Expert Opinions.
That Geico failed to comply with the applicable policy and standards in adjusting plaintiff’s
claim, investigating plaintiff’s claim, evaluating plaintiff’s claim, communicating with the
plaintiff and resolving plaintiff’s claim. That Geico’s failure to comply with the policy and
applicable standards in relation to plaintiff’s claim is part of Geico’s pattern and practice of
similar violations of standards by Geico in other claims.
IV. The Substance of the Grounds of Opinions.
That Geico did not adjust the plaintiff’s claim in accordance with the policy requirements.
That Geico did not adjust the plaintiff’s claim in good faith in that its conduct shows its
evasion of the spirit of the bargain, lack of diligence, slacking off, willful rendering of
imperfect performance of its obligations under the policy.
That Geico did not adjust the plaintiff’s claim in compliance with C.G.S. Section 38-816(6).
That Geico’s lack of compliance with C.G.S. Section 38-816(6), is part of Geico’s pattern
and practice of violating C.G.S. Section 38-816(6), and its counterparts in the NAIC model
act as adopted in other states.
That Geico improperly and inexplicably denied coverage to plaintiff for a claim that was not
made, improperly raised a coverage issue and never informed plaintiff of its resolution,
promised to confirm coverage but never confirmed coverage, and in effect denied coverage
for part of plaintiff’s claim without notifying plaintiff of the denial in any manner. Geico
improperly made an offer of compromise. Geico failed and refused to acknowledge
correspondence and repeatedly requested information and documentation previously
provided to it. Geico asked for irrelevant information and documentation not related to
plaintiff’s claim and failed to take the statement of the plaintiff, conduct an independent
medical exam of plaintiff, or take an examination under oath of the plaintiff to find relevant
information. Geico closed the plaintiff’s claims for lack of interest. Geico failed to
investigate, evaluate, and provide compensation for each and every aspect of plaintiff’s claim
when valuing the plaintiff’s claim. Geico failed to offer prompt, fair and equitable
compensation for plaintiff’s claim. Geico improperly used the CIQ system to generate a
lower value. Geico discounted an uncontroverted medical finding with non-medical
speculation. Geico provided an arbitrary value to plaintiff’s claim.
His testimony will be based upon a review of the publicly available information, discovery
disclosures, deposition transcripts, and pleadings pertaining to plaintiff’s claim and suit to the
extent that the expert finds said information helpful to him in reaching his opinion and
conclusions. His opinion is based upon his education, training and experience in his area of
expertise.
BY______________________________
Frank C. White, Jr.
Commissioner of the Superior Court
2 Crescent Street
East Hampton, CT 06424
DOCKET NO.: MMX-CV19-6023735-S : SUPERIOR COURT
ANN L. GILLESPIE-WHITE J.D. OF MIDDLESEX
V. : AT MIDDLETOWN
GOVERNMENT EMPLOYEES INSURANCE CO.: DECEMBER 11, 2022
CERTIFICATION
This is to certify that the foregoing was mailed or will immediately be mailed or delivered
electronically or non-electronically on December 11, 2022, to all counsel and self-represented
parties of record and that written consent for electronic delivery was received from all counsel
and self-represented parties of record who were or will immediately be electronically served:
Sent via email to: jjnoonan@ryandelucalaw.com
Ryan Ryan Deluca LLP
1000 Lafayette Boulevard Suite 800
Bridgeport, CT 06604
BY: ____________________________
Name: Frank C. White, Jr.
Address: 2 Crescent Street, East Hampton, Ct. 06424
Phone Number: 860 918 1362
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DOCKET NO.: MMX-CV19-6023735-S : SUPERIOR COURT ANN L. GILLESPIE-WHITE J.D. OF MIDDLESEX V. : AT MIDDLETOWN GOVERNMENT EMPLOYEES INSURANCE CO.: DECMEBER 11, 2022 AMENDED PLAINTIFF’S DISCLOSURE OF EXPERT WITNESS Pursuant to Practice Book Sections 13-4, 13-4(a) and 13-15, the plaintiff hereby amends her disclosure that she may call the following expert witness at the time of trial: I. Identity of Expert Witness: Peter Knowe of Knowe Consulting, LLC, 2012 Wilmington Place, Birmingham, Alabama, 35242. II. Field of Expertise and Subject Matter. Insurance claims adjusting and insurance claims management including the investigation of coverage, liability, causation and damages, the valuation of claims, the resolution of claims, and the interactions and communications with insureds and claimants all as required by the insurance policy, industry standards, industry organization standards, insurance carrier internal standards, as well as state standards by statute and/or regulation, state regulator standards, and the National Association of Insurance Commissioners standards. III. The Expert Opinions. That Geico failed to comply with the applicable policy and standards in adjusting plaintiff’s claim, investigating plaintiff’s claim, evaluating plaintiff’s claim, communicating with the plaintiff and resolving plaintiff’s claim. That Geico’s failure to comply with the policy and applicable standards in relation to plaintiff’s claim is part of Geico’s pattern and practice of similar violations of standards by Geico in other claims. IV. The Substance of the Grounds of Opinions. That Geico did not adjust the plaintiff’s claim in accordance with the policy requirements. That Geico did not adjust the plaintiff’s claim in good faith in that its conduct shows its evasion of the spirit of the bargain, lack of diligence, slacking off, willful rendering of imperfect performance of its obligations under the policy. That Geico did not adjust the plaintiff’s claim in compliance with C.G.S. Section 38-816(6). That Geico’s lack of compliance with C.G.S. Section 38-816(6), is part of Geico’s pattern and practice of violating C.G.S. Section 38-816(6), and its counterparts in the NAIC model act as adopted in other states. That Geico improperly and inexplicably denied coverage to plaintiff for a claim that was not made, improperly raised a coverage issue and never informed plaintiff of its resolution, promised to confirm coverage but never confirmed coverage, and in effect denied coverage for part of plaintiff’s claim without notifying plaintiff of the denial in any manner. Geico improperly made an offer of compromise. Geico failed and refused to acknowledge correspondence and repeatedly requested information and documentation previously provided to it. Geico asked for irrelevant information and documentation not related to plaintiff’s claim and failed to take the statement of the plaintiff, conduct an independent medical exam of plaintiff, or take an examination under oath of the plaintiff to find relevant information. Geico closed the plaintiff’s claims for lack of interest. Geico failed to investigate, evaluate, and provide compensation for each and every aspect of plaintiff’s claim when valuing the plaintiff’s claim. Geico failed to offer prompt, fair and equitable compensation for plaintiff’s claim. Geico improperly used the CIQ system to generate a lower value. Geico discounted an uncontroverted medical finding with non-medical speculation. Geico provided an arbitrary value to plaintiff’s claim. His testimony will be based upon a review of the publicly available information, discovery disclosures, deposition transcripts, and pleadings pertaining to plaintiff’s claim and suit to the extent that the expert finds said information helpful to him in reaching his opinion and conclusions. His opinion is based upon his education, training and experience in his area of expertise. BY______________________________ Frank C. White, Jr. Commissioner of the Superior Court 2 Crescent Street East Hampton, CT 06424 DOCKET NO.: MMX-CV19-6023735-S : SUPERIOR COURT ANN L. GILLESPIE-WHITE J.D. OF MIDDLESEX V. : AT MIDDLETOWN GOVERNMENT EMPLOYEES INSURANCE CO.: DECEMBER 11, 2022 CERTIFICATION This is to certify that the foregoing was mailed or will immediately be mailed or delivered electronically or non-electronically on December 11, 2022, to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were or will immediately be electronically served: Sent via email to: jjnoonan@ryandelucalaw.com Ryan Ryan Deluca LLP 1000 Lafayette Boulevard Suite 800 Bridgeport, CT 06604 BY: ____________________________ Name: Frank C. White, Jr. Address: 2 Crescent Street, East Hampton, Ct. 06424 Phone Number: 860 918 1362