In this ordinary breach of contract action by plaintiff Liberty Mutual Fire Insurance Company (Liberty) to recover workers' compensation insurance premiums, defendant LCL Administrators, Inc. (LCL) filed an answer and cross-complaint alleging that Liberty mishandled its claims. The Pleadings On August 8, 2004, Liberty filed a complaint for breach of insurance contracts and common counts, seeking to recover premiums due on a series of workers' compensation insurance policies issued to LCL by Liberty or its predecessor in interest, Employers Insurance of Wausau, A Mutual Company. (d)), and a belief that the contracts of insurance were improperly implemented and interpreted by Plaintiff [Liberty]; as [Liberty] provides responses to discovery, [LCL] will be able to detail the specific areas of breach. "The response referred to "a belief that the contracts of insurance were improperly implemented and interpreted" by Liberty, and gave the policy number of every insurance policy at issue. LCL named 65 witnesses with "knowledge of these facts," none of whom were associated with LCL, but rather were employees of Liberty or hospital and medical providers.

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