BOWMAN, Circuit Judge.
Roy Holst filed a $215,000 claim with his insurer, General Casualty Insurance Companies, after his place of business, Holst Radiator Co., was damaged by a fire on December 28, 1992. On March 8, 1993, General Casualty paid $70,000 on the portions of Holst's claim that were not in dispute at that time.
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