In Coates v. Metropolitan Property and Casualty Insurance Company, the District Court of the Eastern District of Pennsylvania addressed a situation where an insured attempted to name his public adjuster (“PA”) as an expert to testify to the cause of a property damage loss and coverage under the policy. In granting the insurer’s motion in limine to preclude the PA’s report and testimony, the judge found that while the PA meet the “qualification” prong under FRE 702, he failed to meet the “reliability” and “fit” prongs. Accordingly, the PA’s report and testimony were barred. The loss at issue in this
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