BAKER, Chief Judge.
Thomas Downie's insurance policy against loss of personal property required him to give an examination under oath (EUO) upon request before suing his insurance carrier. He submitted a claim and gave two recorded interviews to different adjustors, but refused to submit to the requested EUO.
Because a recorded statement given to an adjustor is not equivalent to an EUO, we hold that such a statement does not constitute substantial compliance...
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