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the insurer's reserve for the file. In Kirchoff, the 8,000 offer represented a 97 reduction in the estimated value of the case. Here, the 400,000 offer represents an 86 reduction in the estimated value of the case when compared to Hartford's reserve on the file. Thus, while the amount of the offer is not as egregious as the amounts involved in Arp and Kirchoff, the question still remains whether Hartford's low offer creates a submissible issue of fact for a jury to determine whether Hartford engaged in bad faith settlement tactics. While this case may fall on the borderline in that regard, it is nevertheless preferable to allow a jury to determine the issue, rather than a judge.

See, e.Appellant's Brief at i ("Ultimately, Hartford intimidated Hammonds into settling for a substantially reduced amount.]