“Plaintiff claims that Defendant acted unreasonably, that is, without proper cause, by failing to conduct a proper investigation of his claim. To establish this claim, Plaintiff must prove all of the following: 1. That Plaintiff suffered a loss covered under an insurance policy issued by Defendant; 2. That Plaintiff properly presented a claim to Defendant to be compensated for the loss; 3. That Defendant, failed to conduct a full, fair, prompt, and thorough investigation of all of the bases of Plaintiff’s claim; 4. That Plaintiff was harmed; and 5. That Defendant’s failure to properly investigate the claim was a substantial factor in causing Plaintiff’s harm. When investigating Plaintiff’s claim, Defendant had a duty to diligently search for and consider evidence that supported coverage of the claimed loss.”
[CACI Jury Instructions [citations omitted]]
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