After a serious accident, victims often assume that an insurance company will “do the right thing” and pay the full value of their claim. In reality, insurers are trained to do the opposite—to minimize payouts and protect profits. Even when policy limits appear straightforward, the road to obtaining every available dollar can be filled with obstacles, technical defenses, and strategic delays.
This is where experienced attorneys make the difference. At Deng Law Center, our mission is to fight relentlessly for policy-limit recoveries, forcing insurers to honor their contractual duties and compensate injured victims to the fullest extent permitted by law.
I. What Does “Policy Limits” Really Mean?
Every insurance policy includes a coverage limit—the maximum amount the insurer will pay for a particular type of claim. For example:
- Auto liability coverage: $15,000/$30,000 (the California minimum), meaning $15,000 per injured person and $30,000 per incident total.
- Commercial or trucking coverage: Often $1 million or more in bodily injury limits.
- Umbrella or excess policies: Additional layers that sit above the primary policy.
While these numbers may look clear on paper, the insurer rarely volunteers to pay the maximum amount. It often requires aggressive advocacy to prove liability, establish damages, and trigger policy-limit obligations.
Deng Law Center has decades of combined experience analyzing insurance layers, identifying hidden excess coverage, and using time-limited demands to compel full payments.
II. Why Insurers Resist Paying Policy Limits
Insurance companies have one core objective—protecting their bottom line. Even when the evidence strongly supports full payout, adjusters are incentivized to settle for less. Their tactics often include:
- Disputing liability: Blaming the victim for partial fault (comparative negligence).
- Minimizing damages: Arguing injuries are “pre-existing” or “minor.”
- Delaying response times: Hoping financial pressure forces early settlement.
- Cherry-picking medical records to undervalue pain and suffering.
By using these methods, insurers seek to close cases cheaply while claiming they acted in good faith. Deng Law Center counters these tactics through meticulous documentation, aggressive communication, and strategic bad-faith positioning.
III. Time-Limited Demands: The Weapon of Choice
One of the most powerful tools in injury litigation is the policy-limit demand letter—a written, time-limited offer giving the insurer a fair opportunity to settle within limits.
If the insurer unreasonably rejects or ignores this demand, and the jury later awards more than the policy limits, the insurer can be held liable for the entire judgment, even the excess portion.
At Deng Law Center, we craft these demands with surgical precision. Each letter includes:
- Clear liability proof.
- Verified medical and financial damages.
- Specific demand amounts and expiration dates.
- Language citing California’s bad-faith precedent (e.g., Comunale v. Traders & General Insurance Co.).
These demands often turn reluctant insurers into cooperative negotiators—because failure to pay on time can expose them to unlimited risk.
IV. The Role of Bad-Faith Law
California law holds insurers to a duty of good faith and fair dealing. When they refuse to settle reasonably within policy limits, they may face bad-faith liability—including punitive damages.
Common bad-faith conduct includes:
- Ignoring evidence that clearly supports the claimant.
- Failing to investigate thoroughly.
- Misrepresenting policy terms or coverage.
- Making unreasonable delay or lowball offers.
Deng Law Center leverages this legal framework to push insurers beyond negotiation—turning their own misconduct into leverage for higher settlements.
V. Complex Scenarios: Multiple Claimants and Limited Coverage
In many cases—such as multi-car crashes or tour bus incidents—several victims share a single policy limit. For instance, if a negligent driver carries $30,000 total coverage but injures three people, insurers must allocate that sum among all claims.
This creates a race to secure fair payment. Victims who act slowly risk receiving less or nothing.
Deng Law Center moves quickly to preserve the client’s position, filing early demands, notifying excess carriers, and objecting to unfair interpleader tactics that attempt to “wash hands” of responsibility.
Our team also evaluates whether other policies—such as an employer’s commercial coverage or permissive-user clauses—can expand available compensation.
VI. Uncovering Hidden Coverage Layers
Often, the “policy limit” the insurer cites is not the whole story. Additional coverage sources may include:
- Umbrella or excess policies held by corporations or vehicle owners.
- Employer coverage if the at-fault driver was on duty.
- Household member policies that extend permissive use coverage.
- Uninsured/underinsured motorist (UM/UIM) benefits from the victim’s own insurance.
- Rental car or credit card policies with supplemental coverage.
Through forensic policy analysis and subpoena power, Deng Law Center uncovers hidden layers that can multiply recovery far beyond initial expectations.
VII. Building the Case for Maximum Value
To justify policy-limit recovery—or even exceed it through bad-faith exposure—lawyers must prove not only fault but also severity.
Our strategy includes:
- Comprehensive medical documentation (imaging, surgical reports, prognosis).
- Life-care planning for long-term disabilities.
- Economic projections for lost earning capacity.
- Emotional-distress testimony and psychological evaluations.
- Expert accident reconstruction and biomechanics analysis.
By demonstrating the full human and financial toll, Deng Law Center compels insurers to recognize that delay only increases their ultimate exposure.
VIII. When Policy Limits Aren’t Enough
Sometimes, damages far exceed coverage. In such cases, we pursue personal asset claims against negligent defendants, corporate employers, or third parties responsible for contributing factors (e.g., maintenance failures, defective products).
We also coordinate structured settlements, medical liens, and special-needs trusts to maximize net recovery for severely injured clients.
Even when facing limited insurance funds, Deng Law Center ensures every dollar is accounted for and every avenue explored.
IX. Case Example
A client suffered multiple fractures in a commercial van collision. The insurer initially offered $100,000—the alleged policy limit. Through investigation, Deng Law Center discovered a $1 million umbrella policy tied to the same insured company.
After a detailed demand citing bad-faith exposure, the insurer paid the full $1.1 million, avoiding a potential excess judgment. The client used those funds to cover surgeries and long-term rehabilitation.
This outcome reflects our philosophy: thorough research and strategic timing turn “impossible” cases into full-limit recoveries.
X. The Deng Law Center Advantage
What distinguishes Deng Law Center in policy-limit litigation:
- Aggressive demand strategy: Time-sensitive offers with airtight evidence.
- Regulatory precision: Deep understanding of California Insurance Code §790.03 (unfair claims practices).
- Multilingual advocacy: Serving English- and Chinese-speaking clients seamlessly.
- Data-driven negotiation: Quantitative modeling of damages and liability risk.
- Trial readiness: We prepare every case as if it will go before a jury—insurers notice and pay attention.
When insurers see Deng Law Center on the file, they understand that delay tactics will fail—and that refusing a fair offer may expose them to even greater financial danger.
If you or a loved one are fighting an insurance company that refuses to pay fair value, don’t give up. The law provides leverage—when used by the right attorney.
Call Deng Law Center today for a free consultation. We work on a contingency basis—no fees unless we win.
Contact Deng Law Center
📞 Phone: (626) 280-6000
🌐 Website: www.DengLawCenter.com
🏢 Rosemead Office: 8811 Garvey Ave, Suite 201, Rosemead, CA 91770
📍 Irvine Office: Consultations by appointment only