Cummings v. Safe Auto Insurance Company et al

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
WILLIAM CUMMINGS,
Plaintiff
v.
SAFE AUTO INSURANCE COMPANY; :
and SAFE AUTO INSURANCE
COMPANY a/k/a d/b/a Safe Auto
Insurance alkla dlb/a Safe Auto,
Defendants
No. 3:23cv1325
(Judge Munley)
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MEMORANDUM ORDER
Before the court for disposition are two pending discovery motions filed by
Plaintiff William Cummings and Defendants Safe Auto Insurance Company and
Safe Auto Insurance Company a/k/a d/b/a Safe Auto Insurance a/k/a d/b/a Safe
Auto's (hereinafter "Safe Auto"). 	Plaintiff moves the court to: 1) overrule Safe
Auto's objections to plaintiff's corporate designee deposition notice; 2) compel
testimony by a corporate designee on those matters; and 3) compel production of
the requested documents. (Doc. 30). Safe Auto opposes plaintiff's motion and
has filed a motion for a protective order. (Doc. 31 ).
By way of brief background , on September 1, 2021 , Plaintiff William
Cummings sustained severe personal injuries in an automobile collision in Port
Jervis, New York while riding as a passenger in a vehicle owned or leased by
Rachel Orazzi. Cummings v. Safe Auto Ins. Co., No. 3:23CV1325, 2024 WL
Case 3:23-cv-01325-JKM Document 36 Filed 02/10/26 Page 1 of 18

3928890, at *1 (M.D. Pa. Aug. 23, 2024 ). 1 At the time, Orazzi had an automobile
policy issued by Safe Auto. Given that he was a passenger in the vehicle,
plaintiff was insured under the policy. 	Plaintiff did not maintain his own
automobile insurance, making the Safe Auto Policy first in priority for first party
benefits. 	As a result, plaintiff submitted a claim for first party medical benefits
under the policy.
Safe Auto paid plaintiff $5 ,000.00 in personal injury protection ("PIP")
benefits, the statutory minimum under 75 PA. CONS. STAT . § 1711 (a).
Accordingly, Safe Auto closed the medical benefits portion of plaintiff's PIP claim
on or about December 27, 2021.
Later, Safe Auto asserted its right of subrogation or reimbursement against
plaintiff through a medical payments lien in the amount of $5 ,000.00 and notified
plaintiff of this lien on March 28, 2022. (J..gJ 	Plaintiff alleges that Safe Auto's right
of subrogation or reimbursement asserted through its agent EXL and/or Trumbull
Services ("EXL") is improper as it seeks to deprive him of the full amount of his
PIP benefits. Plaintiff further alleges that if he recovered in a tort action against
the tortfeasor, he would have to potentially pay back the money he received from
1 These b ri ef background facts are mainly drawn from the court's opinion denying Safe Auto's
motion to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure.
2
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Safe Auto. 	Plaintiff posits that Safe Auto is not entitled to such subrogation or
reimbursement under Pennsylvania law.
At some point, plaintiff received a monetary settlement from the tortfeasor.
Plaintiff's counsel, however, was forced to keep funds from the settlement in
escrow for well over a year to cover the amount of the lien. 	Based upon these
facts , plaintiff sued Safe Auto for breach of contract and statutory bad faith under
42 PA. CONS. STAT. § 8371 ("Section 8371 ").
During discovery, plaintiff served upon Safe Auto a notice pursuant to Rule
30(b)(6) of the Federal Rules of Civil Procedure seeking the oral deposition of a
corporate designee by video ("30(b )(6) Notice"). (Doc., Pl. Motion ,I 3). 	The
30(b )(6) Notice also sought information concerning other claims involving Safe
Auto's insureds. Safe Auto objected to most of the topics identified in the
30(b )(6) Notice as well as the accompanying document requests. 2 (!.fL. ,I 4 ). 	To
narrow the dispute and minimize court intervention, plaintiff limited the contested
items to fourteen (14) matters of inquiry - numbers 7, 13, 20-29 and 32-33 - and
nineteen (19) document requests - numbers 6, 11 , 12 , 18-29 and 31-34. (Doc.
30, ,I 9) .
2 The court held a telephone conference to discuss these issues on July 11 , 2025 and directed
the parties to brief their respective positions . (Doc. 29).
3
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Safe Auto argues that plaintiff seeks broad discovery into unrelated claims,
including those involving subrogation vendors not involved in plaintiff's case and
Safe Auto's practices after its acquisition by Allstate Insurance Company when it
began handling subrogation internally. (Doc. 31, ,I 27).
Rule 26 of the Federal Rules of Civil Procedure permits parties to obtain
discovery of "any nonprivileged matter that is relevant to [a] claim or defense and
proportional to the needs of the case." FED R. CIv. P. 26(b )(1 ). 	In assessing
proportionality, courts consider among other factors the importance of the issues
at stake, the parties' relative access to relevant information, and whether the
burden or expense of the proposed discovery outweighs its likely benefit. kl
Notably, "[i]nformation within th[e] scope of discovery need not be admissible in
evidence to be discoverable." Id.
"In the context of discovery, it is well-established that a party wishing to
obtain an order of protection over discovery material must demonstrate that good
cause exists for the order of protection." Pansy v. Borough of Stroudsburg, 23
F.3d 772, 786 (3d Cir. 1994) (citation and internal quotation marks omitted).
"Good cause is established on a showing that disclosure will work a clearly
defined and serious injury to the party seeking closure." kl (citations and internal
quotation marks omitted). 	Additionally, "[t]he injury must be shown with
specificity [as] [b]road allegations of harm, unsubstantiated by specific examples
4
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or articulated reasoning , do not support a good cause showing ." kt (citations and
internal quotation marks omitted).
The Third Circuit has adopted a general balancing test for courts to apply
when considering whether to grant confidentiality orders:
Id . at 787.
[T]he court . .. must balance the requesting party's need for
information 	against 	the 	injury 	that 	might 	result 	if
uncontrolled disclosure is compelled .. . Once the court
determines 	that the 	discovery 	policies 	require 	that the
materials be disclosed , the issue becomes whether they
should be disclosed only in a designated way ... 	Whether
this 	disclosure 	will 	be 	limited 	depends 	on 	a 	judicial
balancing of the harm to the party seeking protection (or
third 	persons) 	and the 	importance of disclosure 	to 	the
public.
The Court of Appeals has emphasized that "Courts also have a great deal
of flexibility in crafting the contents of protective orders to minimize the negative
consequences of disclosure and serve the public interest simultaneously ." kt
Deposition of a corporate designee - 	Safe Auto contends that it did not
object to discussion of its policies and procedures generally or what happened in
plaintiff's own case specifically. (Doc. 31 , ,m 80 - 81 ). 	Safe Auto further maintains
that it had identified a corporate designee to address these issues at deposition.
(kt ,m 80 - 81 ). Nonetheless, Safe Auto objects to having its corporate designee
testify on the topics of other claims unrelated to plaintiff's case. (kl..: 1J 82).
5
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Based on the parties' submissions , the discovery dispute concerns the
topics of the proposed corporate designee testimony, not the deposition itself.
Those topics therefore warrant discussion.
Discoverability of information sought by plaintiff- Plaintiff maintains that his
30(b )(6) Notice is narrow in scope and limited to two (2) years prior to the subject
accident to present and only those claims which satisfy three factors , specifically,
that the claims involve: (1) a Pennsylvania policy; (2) an out-of state accident;
and (3) Safe Auto seeking subrogation on a first-party claim. (Doc. 32 , Pl. Br. in
Supp. at 12-13).
Safe Auto opposes, arguing that information regarding other claims is not
discoverable in an insurance bad faith case as such information is irrelevant.
(Doc. 31 , ,m 40-41) (collecting cases). The court disagrees with Safe Auto.
In the Eastern District of Pennsylvania, the Honorable R. Barclay Surrick
rejected similar arguments made by a defendant. Saldi v. Paul Revere Life Ins.
Co ., 224 F.R.D . 169, 175-77 (E.D . Pa . 2004). 	According to Judge Surrick:
[W]e disagree with Defendant's assertion that the case law
broadly limits discovery in all [bad faith insurance cases] .
Rather, we conclude that courts have consistently held that
when 	a 	bad 	faith 	policy 	or 	practice 	of 	an 	insurance
company is applied to the specific plaintiff, the plaintiff is
entitled to discover and ultimately present evidence of that
policy or practice at trial in order to prove that the insurer
intentionally injured the plaintiff and to show the insurer's
reprehensibility and recidivism in order to assist the jury in
calculating 	appropriate 	punitive 	damages. 	[State 	Farm
6
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Mut. 	Auto. 	Ins. 	Co. v. 	Campbell , 538 U.S. 408, 	422-24
(2003)] . As the Supreme Court explained in State Farm,
evidence of the lawful out-of-state conduct of the defendant
"may 	be 	probative 	when 	it 	demonstrates 	the
deliberateness and culpability of the defendant's action in
the State where it is tortious" so long as the "conduct had
a nexus to the specific harm suffered by the plaintiff." ~ 	at
1522. The Court's main interest was to prevent the due
process 	problems 	created 	when 	the 	jury 	punished 	the
defendant 	for 	conduct 	that 	"bore 	no 	relation 	to 	the
[plaintiff's] 	harm . 	A 	defendant's 	dissimilar 	acts,
independent 	from 	the 	acts 	upon 	which 	liability 	was
premised , 	may 	not 	serve 	as 	the 	basis 	for 	pun itive
damages ." kl
Id . at 176-77.
Based on the foregoing , the court in Saldi allowed other similar cases to be
subject to discovery. kl at 178. That is because Mr. Saldi , the plaintiff, submitted
documents showing that there was a sufficient nexus between the actions of the
defendant in other cases and the specific harm suffered by him . ~ 	; see also
State Farm, 538 U.S. at 422 ("Lawful out-of-state conduct may be probative
when it demonstrates the deliberateness and culpability of the defendant's action
in the State where it is tortious , but that conduct must have a nexus to the
specific harm suffered by the plaintiff ." ))
Here, the central issue is whether the requested discovery is likely to yield
relevant evidence and whether its potential benefit outweighs the burden or
expense to Safe Auto. 	Because discovery determinations are case-specific, the
court will conduct its own individual balancing analysis under Pansy to assess
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the relevance of the plaintiff's requests . 	In evaluating relevance , the court first
reviews the elements of Pennsylvania's bad faith statute.
The Pennsylvania Supreme Court has held that "to prevail in a bad faith
insurance claim pursuant to Section 8371 , a plaintiff must demonstrate, by clear
and convincing evidence,3 (1) that the insurer did not have a reasonable basis for
denying benefits under the policy and (2) that the insurer knew or recklessly
disregarded its lack of a reasonable basis in denying the claim ." Rancosky v.
Washington Nat'I Ins. Co ., 170 A.3d 364 , 377 (Pa. 2017); see 42 PA. CONS. STAT.
§ 8371 (authorizing recovery of punitive damages, court costs, and attorney fees
for an insurance company's bad faith toward an insured). 	Bad faith liability can
be founded on an insurance company's "lack of good faith investigation into
facts , and failure to communicate with the claimant. " Condio v. Erie Ins. Exch .,
899 A.2d 1136, 1142 (Pa. Super. Ct. 2006) (citation and quotation marks
omitted).
Under State Farm , evidence of Safe Auto's conduct in other cases is
relevant and potentially admissible only if it bears a sufficient nexus to the
conduct at issue in this case.
3 Clear and convincing evidence is the "highest standard of proof for civil claims[.]" Berg v.
Nationwide Mut. Ins. , 189 A.3d 1030, 1037 (Pa . Super. Ct. 2018) (internal quotation marks and
citation omitted) . It "requires evidence clear, direct, weighty, and convincing as to enable the
trier of fact to come to a clear conviction , without hesitancy of the truth of the precise facts in
issue. " kt (internal quotation marks and citation omitted ).
8
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Plaintiff's asserts that Safe Auto maintained a policy and practice of
improperly asserting unlawful liens. (Doc. 1-1, Compl. ,r 42). 	Per plaintiff, this
practice reflects Safe Auto's self-interest, ill-will, and knowledge that its lacks a
reasonable basis to assert such liens. (~) 	Through a subpoena, plaintiff
obtained documents from EXL related to ten (10) claims involving Pennsylvania
Safe Auto policies and out-of-state accidents in which subrogation was asserted
on first-party benefits but no recovery was obtained. (See Doc. 30-4, Ex. D). 	The
documents reflect that Safe Auto referred plaintiff's claim to EXL, its subrogation
agent, despite noting in its own claims records that no subrogation potential
existed. (See Doc. 32 , Pl. Br. in Supp. at 5-9; see also Doc. 30-4, Ex. D). 	Plaintiff
further asserts that EXL's notes were entered in a system known as
"Subrosource" which appears to synchronize entries with Safe Auto's internal
claims notes. (Pl. Br. in Supp at 4; Ex. D at ECF pp. 1-9).
The evidence offered by plaintiff warrants further inquiry into Safe Auto's
handling of other first-party PIP subrogation claims involving Pennsylvania
policies and out-of-state accidents. This evidence suggests that plaintiff's
discovery requests will likely lead to relevant information. 	Specifically, the
information may show that Safe Auto acknowledged the absence of subrogation
rights while pursuing subrogation . The same evidence further suggests that this
conduct was not an isolated incident or mere mistake. 	Rather, it may reflect a
9
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repeated and objectionable business practice. 4 This evidence also bears directly
on Safe Auto's state of mind. 	Such an inquiry is relevant as to whether Safe
Auto acted with reckless disregard of the absence of a reasonable basis under
Rancosky. 	It is likewise relevant to reprehensibility and recidivism for purposes
of punitive damages under State Farm. 	Thus, that evidence plaintiff is seeking
here is relevant to this bad faith claim .
Safe Auto argues that factual differences and varying circumstances render
discovery of other claims irrelevant. This argument is not persuasive. Plaintiff
seeks discovery limited to claims involving Pennsylvania policies and out-of-state
accidents in which Safe Auto sought reimbursement for first-party benefits.
Because these requests are narrowly tailored, the discovery relates to materially
identical circumstances and similar legal issues present here. As plaintiff
asserts, any attempt to seek subrogation for first-party benefits paid under a
Pennsylvania policy arising from an out-of-state accident would be objectively
unlawful as such recovery is prohibited by 75 PA. CONS. STAT. § 1720. 	(See Doc.
32 , Pl. Br. in Supp. at 20-21 ).
Having concluded that other claims involving a Pennsylvania policy, an out
of state accident, and Safe Auto's pursuit of subrogation on a first-party claims
4 The relevant inquiry is not whether any amounts were ultimately recovered through
subrogation ; rather, whether Safe Auto attempted to recover monies to which it had no
entitlement.
10
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are relevant to plaintiff's bad faith claim, the court next turns to the specifics of
each of plaintiff's requests.
Files related to the ten claims identified by EXL - 	Plaintiff seeks the files
pertaining to the ten claims Safe Auto referred to EXL for subrogation. (Doc. 32,
Pl. Br. in Supp at 14). EXL has already provided Safe Auto with the claim
numbers for those files and Safe Auto has acknowledged that it reviewed them.
(Doc. 31 , 1J1J 23-26). Accordingly, producing the files for those ten (10) claims is
not unduly burdensome. The fact that Safe Auto may need to redact names or
other identifying personal information does not render the production
burdensome.
Pennsylvania policies involving out of state accidents - 	Plaintiff seeks
discovery of claims involving Pennsylvania policies and New York accidents.
(See Doc. 32, Pl. Br. in Supp. at 16-17). 	Plaintiff also seeks discovery of claims
involving Pennsylvania policies and all out-of-state accidents. (lf!.:.) 	Safe Auto
takes the position that, if discovery of other claims is permitted at all , it should be
limited to claims in the State of New York. (See Doc. 31, 1J 86). 	Nonetheless,
Safe Auto indicated that it had identified a total of 229 subrogation assignments
which were made during the time period between September 1, 2019 and July
15, 2025 under a Pennsylvania automobile insurance policy for an accident in
11
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another state in relation to the payment of first-party medical expenses. (Doc. 31,
,i 36). 5
As reflected in the claim notes for the ten claims handled by EXL,
regardless of whether the accident occurred in Maryland, Nevada, New Jersey or
Delaware, the conclusion was the same: Safe Auto had no subrogation rights
under the Pennsylvania policies. (See Doc. 30-3 at ECF p. 4 ). 	Accordingly, the
information plaintiff seeks is relevant to an alleged repeated and objectionable
business practice and is therefore discoverable.
Other claims where Safe Auto acted as its own subrogation agent - 	Plaintiff
contends that other claims are also relevant and discoverable where Safe Auto
acted as its own subrogation agent for Pennsylvania policies involving out-of-
state accidents , regardless of whether any recovery was made. (Doc. 32 , Pl. Br.
in Supp. at 15). The court agrees with plaintiff. See Berg, 189 A.3d at 1055
5 Per Safe Auto , the subrogation assignments were made across 12 states as follows : (122) in
New York; (41) in New Jersey; (27) in Delaware ; (13) in Maryland ; (11) in Florida ; (4) in North
Carolina; (3) in Georgia; (2) in South Carolina ; (2) in Massachusetts; (1) in Connecticut; and
(1) in Ohio. (Doc. 31 , ~lil 36 , 37)
Safe Auto argues that determining whether its subrogation assignments were legitimate in
other states would require reviewing the facts and applicable law for each of the 229 claims.
(kl ,I 71 ). Per Safe Auto, this process could also require a choice of law analysis . (kl ,I 72) .
Safe Auto further contends that litigating the merits of 229 subrogation assignments could
result in a series of "mini trials" under other states' laws. (kl ,I 73). 	The court is not convinced
that these concerns should preclude plaintiff from obtaining discovery.
12
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(holding that "a finding of bad faith under section 8371 may be premised upon an
insurer's conduct occurring before, during or after litigation ." ).
Information that Safe Auto obtained while pursuing PIP subrogation on its
own behalf in these cases is directly relevant to whether Safe Auto had notice
that such subrogation was unlawful before it pursued subrogation in plaintiff's
case. 	The United States Supreme Court has instructed that, in assessing
whether defendant's prior transgressions demonstrate recidivism warranting
punishment, "courts must ensure the conduct in question replicates the prior
transgressions ." State Farm, 538 U.S. at 423. 	The evidence plaintiff seeks may
show that Safe Auto's conduct in this case mirrors its earlier conduct. 	Such
information is thus discoverable.
Timeframe - 	Because Safe Auto has already identified 229 subrogation
assignments made between September 1, 2019 and July 15, 2025, it has already
located the responsive claims files and reviewed and categorized them by state.
All that remains is the ministerial task of making any necessary redactions and
producing the files .
Expense of the proposed discovery - The party asserting undue burden or
expense must specifically demonstrate it , while the party seeking discovery must
show its likely benefit. FED. R. CIv. P. 26, Advisory Committee Notes, 2015
13
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Amend . With respect to this factor, the court considers the overall balance
between the burden of the proposed discovery and its anticipated benefit. ~
Here, Safe Auto argues that plaintiff's discovery requests concerning other
claims files are disproportionate to the needs of this case because of the
purported amount-in-controversy. (Doc. 35 , Def. Br. in Opp. at 24- 30). 	Safe
Auto's argument overlooks the nature of plaintiff's claims and the remedies
available under Pennsylvania law. See 42 PA. CONS . STAT . § 8371 (allowing
recovery of attorney's fees , interest, and punitive damages for bad faith conduct) .
This court previously held in ruling on Safe Auto's motion to dismiss that:
Here, plaintiffs complaint alleges the following damages:
emotional disturbance, potentially lifelong and foreseeable ,
needless 	expenses, 	unnecessary 	delay 	and 	hardship,
deprivation of due and owning funds which had to remain
in escrow, and the full amount and value of PIP benefits.
(Doc. 	1-1 , ,m 	65-66). These 	damages 	go 	above 	and
beyond the PIP limits which defendants eventually paid to
the plaintiff. Accordingly, this breach of contract claim will
not be dismissed on the basis that plaintiff has already
been paid the limits to which he was entitled . See, e.g. ,
Amitia v. 	Nationwide Mut. Ins. Co., No . 3:08cv335, 2009
WL 	111578 	at 	*3 	(M .D. 	Pa. 	Jun. 	7, 	2013) 	(allowing
insurance breach of contract claim to proceed where the
insurer had paid the benefits under the policy but pla intiff
sought 	damages 	different 	from 	the 	benefits 	such 	as
compensation for emotional distress).
Cummings, 2024 WL 3928890 at * 3.
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Accordingly, to the extent Safe Auto argues that the amount in controversy
is limited to $5 ,000, the nature of the case reflects an amount in controversy that
could far exceed $5 ,000 when attorney's fees , interest, and punitive damages
are contemplated .
Turning to the cost of compliance with plaintiff's discovery requests , Safe
Auto contends that responding to plaintiff's discovery would be unduly
burdensome. 	Specifically, Safe Auto asserts that reviewing 229 files involving
subrogation assignments to locate the relevant information and redact
confidential and privileged information would cost between $412 ,200 and
$583 ,950. (Doc. 35 , Def. Br. in Opp. at 25-26). 	According to Safe Auto , these
estimates are based on average hourly rates of $150 for paralegals and $300 for
attorneys. (kl at 27 n.14) (citing cases related to the reasonableness of the
hourly rates) . Safe Auto also maintains that the review would take at least ninety
days to complete. 6 (kl)
Safe Auto further argues that its claims system lacks a search function that
would allow it to identify subrogati on demands or responses in cases involving
Pennsylvania automobile insurance policies and out-of-state accidents. (kl at 7).
6 Pe r Safe Auto reviewing those files and redacting confidential and privileged information
would take approximately 1,832- 2,519 hours. (Doc. 31 -3, ,I 5) . Specifically, Safe Auto
estimates that producing each of the 229 claim files would take: 1) 2 to 3 attorney hours per file
to review each fi le for responsiveness; 2) 2-3 hours of attorney time per file to appropriately
redact privileged information ; and 3) 4-5 hours of paralegal ti me per file to appropriately redact
confidential and personal information . (Doc. 31-3 at ,r,r 10 , 12 , 14).
15
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As a result, Safe Auto asserts that it would be required to conduct a manual
review of each file . (~) 	Lastly, Safe Auto requests that, if discovery of other
claims is permitted, it be limited to written discovery rather than a corporate
designee deposition . (Doc. 35 Def. Br. in Opp. at 31 ). Safe Auto further requests
that plaintiff be required to bear 50 percent of the cost associated with conducting
the discovery. 7 (~)
After careful review of the parties' submissions, the court concludes that
cost sharing is not warranted . Generally, a responding party is presumed to bear
its own costs of complying with discovery requests . Oppenheimer Fund, Inc. v.
Sanders, 437 U.S. 340, 358 (1978). 	Here, Safe Auto has already iden ti fied the
229 subrogation assignments and the corresponding files are therefore
accessible. To the extent Safe Auto raises concerns about attorney time and
expense, the tasks identified are delegable to less experienced professionals.
See Ursic v. Bethlehem Mines, 719 F.2d 670, 677 (3d Cir. 1983) (The Third
Circuit does not "approve the wasteful use of highly skilled and highly priced
talent for matters easily delegable to non-professionals or less experienced
associates ... 	A Michelangelo should not charge Sistine Chapel rates for
7 Rule 26(c)(1 )(B) "include[s] an express recognition of protective orders that allocate
expenses for disclosure or discovery . . . Recognizing the authority does not imply that cost-
shifting should become a common practice. Courts and parties should continue to assume that
a respond i ng party ordinarily bears the costs of responding ." F ED. R. CIv. P. 26 , Advisory
Committee Notes, 2015 Amend .
16
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painting a farmer's barn ." ). 	Plaintiff's discovery requests are therefore neither
unduly burdensome nor disproportionate to the needs of the case.
In sum, the requested discovery is proper. 	Accordingly, it is hereby
ORDERED that:
1) Plaintiff's motion to compel discovery, (Doc. 30), is GRANTED;
2) Safe Auto's motion for protective order, (Doc. 31 ), is DENIED;
3) Safe Auto shall designate and allow a corporate designee to testify on the
topic of Pennsylvania Safe Auto policies and out-of-state accidents in which
subrogation was asserted on first-party benefits;
4) Safe Auto shall produce the files related to the 229 subrogation
assignments it had identified;
5) The discovery is limited to the time period between September 1, 2019 and
July 15 , 2025;
6) As applicable, Safe Auto shall produce a privilege log that identifies with
sufficient specificity any material withheld on the basis of a claimed
privilege or protection; and
7) The case management deadlines are extended as follows :
a. 	Discovery shall be completed by May 11 , 2026;
b. 	Plaintiff's experts reports are due by May 11, 2026;
c. 	Dispositive motions are due by June 5, 2026;
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d. 	Safe Auto's expert reports are due by June 12 , 2026.
18
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