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Insurance Coverage

Whether pre-suit or in active litigation, our team counsels insurers in all matters of insurance coverage and bad faith liability, delivering efficient and effective results. MMM’s Insurance Coverage team provides assistance in three major areas.

Coverage Analysis

We are well-versed in evaluating coverage under all varieties of policies, including commercial general liability, commercial auto, errors and omissions, directors and officers, employment practices liability insurance, commercial property, theft, excess and umbrella policies, personal lines policies, and more. The team also regularly advises clients on the likelihood of coverage under Georgia law and drafts coverage opinions and reservations of rights.

Time-Limited Demands

We routinely evaluate time-limited, policy-limits demands (often called Holt demands in Georgia) for our clients. Georgia is a hotbed of bad faith litigation with a well-earned reputation for being insured-friendly and producing large bad faith verdicts. Our team is equipped to analyze an insurer’s risk for extra-contractual exposure and handle an investigation of the insured’s alleged liability and claimant’s purported damages. MMM also counsels insurers on when and under what circumstances an insurer may have fiduciary duties to an insured.


Our team is comprised of veteran litigators who specialize in insurance coverage and bad faith litigation. We have brought declaratory judgment actions for our clients on a wide variety of matters, including coverage, exclusions, conditions, and limits. We have also defended insurers in a wide variety of civil actions, including first party and third party coverage and bad faith actions in state and federal courts.

Ways We Can Help

  • Providing coverage analysis, drafting coverage opinions, and drafting reservations of rights
  • Analyzing time-limited, policy-limits demands (or Holt demands) and counseling clients on minimizing the risk of extra-contractual exposure
  • Conducting Examinations Under Oath (EUOs)
  • Prosecuting declaratory judgment actions
  • Defending coverage actions
  • Defending bad faith litigation in third party liability cases
  • Counseling insurers on when and under what circumstances an insurer may have fiduciary duties to an insured
  • Defending bad faith litigation in first party cases under O.C.G.A. § 33-4-6