“Plaintiff claims that Defendant breached the obligation of good faith and fair dealing by failing to reasonably inform him of his rights and obligations under an insurance policy. To succeed, Plaintiff must prove all of the following: 1. That Plaintiff suffered a loss covered under an insurance policy with Defendant; 2. That Defendant[denied coverage for/refused to pay Plaintiff’s loss; 3. That under the policy Plaintiff had the [right/obligation] to [e.g., “to request arbitration within 180 days”]; 4. That Defendant did not reasonably inform Plaintiff of his [right/obligation] to []; 5. That Plaintiff was harmed; and 6. That Defendant’s failure to reasonably inform Plaintiff was a substantial factor in causing his harm.”
[CACI Jury Instructions [citations omitted]]
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