Dilon Med. Supply Corp. v. Travelers Ins. Co

In Dilon Med. Supply Corp. v. Travelers Ins. Co. (7 Misc 3d 927 [Civ Ct, Kings County 2005]) the court stated that "when a claimant submits bills to an insurer for payment, the claimant, who stands in the shoes of his assignor, must deal in good faith and cooperate with the insurer if it wants to get paid" (id. at 930). The court further outlined a good faith duty with respect to responses to verification requests, noting that "even if the claimant believes it cannot or need not comply with the insurer's request, the claimant still has a duty to communicate with the insurer regarding the request" (id. at 931).