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13. The aforesaid outrageous conduct by Defendant
TRAVELERS was done intentionally for the purpose of
depriving Plaintiff of money due him and to inflict
upon him severe emotional distress.
* * * * * * *
COUNT III
* * * * * * *
16. In its refusal to pay uninsured motorist
benefits to Plaintiff, Defendant TRAVELERS has violated
public policy as well as Hawaii Revised Statutes
Chapter 431-13 which states that no insurer doing
business in this State shall engage in unfair claim
settlement practices.
COUNT IV
* * * * * * *
18. Hawaii Revised Statutes Section 480-2
provides that unfair methods of competition, and unfair
and deceptive acts or practices in the conduct of any
trade or commerce are unlawful.
19. Defendant’s failure to pay Plaintiff the
uninsured motorist benefits to which he was entitled,
or to provide legally sufficient reasons for denying
payment, was an unfair practice as set forth in Hawaii
Revised Statutes Section 431:13-103(a)(1)(A) and
Section 480-2, entitling Plaintiff to an award of
general and special damages.
* * * * * * *
COUNT V
* * * * * * *
25. At the time of issuance of the policy
described above, the promises to pay such benefits to
Plaintiff were made by Defendant TRAVELERS INSURANCE, *
* *, with no intention of performing them or
interpreting in good faith such terms and provisions.
Defendant and each of them knew such promises and
representations were false and were made with the
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