Wednesday, May 8, 2019 from 4:30 PM to 5:30 PM MDT
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Terrace Tower 
5619 DTC Parkway - Auditorium
free parking on upper deck of garage
Greenwood Village, CO 80111

Driving Directions 


Bo Donegan 
Colorado Defense Lawyers Association 

Join us for Part 3 of an informative Bad Faith CLE 
End-Stage of the Bad Faith/Statutory Delay or Denial Case 

Wednesday, May 8 at 4:30
Happy Hour to Follow

Presented by 

Karen Hannah Wheeler, Esq., Wheeler Law, P.C.
Jon Sands, Esq., Sweetbaum Sands Anderson PC


1 CLE Credit Applied For

CLE Addressing the End-Stage of the Bad Faith/Statutory Delay or Denial Case 

  • Trial tactics in non-bifurcated trial to offset bias against insurers (e.g., how to present adjuster's "evaluation" and handling of claim in best light possible, and to educate the jurors on role of adjuster)
  • Pros and Cons of taking position that “entire claim file” should be an exhibit; are letters from plaintiff’s counsel really “business records” of carrier?
  • Reptile and similar tactics - what to watch for and how to combat them (e.g., "my client has paid insurance premiums for years, and the one time she needs the benefit. . . ")
  • How to identify and develop a "bad guy" for trial from a defense perspective
  • Arguments for and against non-stock jury instructions by plaintiff and defendant (including "fairly debatable" instruction, time period of BF claims, etc.)
  • Verdict forms and the order of questions on the forms

Thank you and hope to see you there.

Heather Salg, Esq. CDLA Insurance Coverage / Bad Faith Committee Chair