Ill. Pattern Jury Instr. (Civil) 710.05

In determining whether [name of insurance company] acted in bad faith in failing to settle

[name of injured person]'s claim against name of insured within the policy limits, you may consider

what the evidence shows concerning the following factors:

1. What [name of insurance company] [and its agent(s)] knew or should have kno wn

concerning the probability of a verdict in favor of [name of injured person] if [name of injured

person]'s claim against [name of insured] was not settled, and what [name of insurance company]

[and its agent(s)] knew or should have known concerning the amount by which such a verdict

might or might not exceed the policy limits;

[2. The willingness of [name of insurance company]'s (and its agent's(s')) and [name of

injured person] to negotiate;]

[3. The reasonableness of the negotiating parties' conduct during the negotiations;]

[4. The extent of [name of insurance company]'s (and its agent's(s')) investigation of [name

of injured person]'s claim;]

[5. [Name of insurance company]'s proper consideration of, or its failure to properly

consider, the advice of counsel;]

[6. (Insert here any other factor or factors which the court rules are supported by the

evidence and are legally relevant to a determination of the insurer's bad faith.)]