IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
                                DIVISION OF ST CROIX
   GUARDIAN INSURANCE COMPANY
                                                           CIVIL CASE NO 8X 19 CV 110
                         Plaintiff,
               v                                    ACTION FOR DECLRATORY JUDGMENT

   RAMZY ABDALLAH
                                                              Cite as 
2021 VI Super 20
                         Defendant
 Mark D Hodge, Esq
 HODGE & HODGE
 St Thomas U S VI
 Attorneyfir Plating}r

 Yohana M Manning,Esq
 MANNING LEGAL SERVICES P C
 St Croix, U S V I
 Attorneyfor Defendant

 BRADY, Douglas A , Judge

                           MEMORANDUM OPINION and ORDER
1! 1    Before the Court is Plaintiff/Counter Defendant Guardian Insurance Company’s Motion
for Partial Reconsideration of the Court’s December 18, 2020 Order Denymg in Part Plaintiff‘s
Motion to Dismiss Defendant’s Counterclaims Defendant Ramzy AbdalIah has filed no response
By its December I8, 2020 Order the Court found that five of the six claims of Abdallah’
                                                                                                   s
Countcrclaim sufficiently set forth short and plain statements of those claims, adequate to put
Guardian on notice ofclaims brought against it, denying Guardian’s Moti0n to Dismiss as to those
claims By its present Motion for Reconsideratlon, Guardian asserts that it is entitled to reliefunder
V I R Civ P 6 4(b) (3) and (4) to correct a clear error of law, and because the Conn
                                                                                          failed to
address issues specifically raised in Guardian’s Motion to Dismiss For the reasons set forth
                                                                                            herein,
the Court w111 grant Guaxdian’s Motion and dismiss Defendant/Counter Plaintiff
                                                                                       Abdallah’s
Counterclaim in its entirety

1! 2   Further, it appears that there are no genuine issues of material fact in dispute with regard
to Guardian’s Complaint seeking declaratory judgment and specific performance by Abdallah
                                                                                                  of
  Guardian Insurance Company v RamzyAbdaIIah SX 19 CV 110
  Memorandum Opinion and Order Granting Plaintiff’s Motion for Partial Reconsideration
  Page 2 of 7
                                                                               
2021 VI Super 20
 Personal Auto Policy No PAP327333 (Policy) between the parties This matter will therefore
 come on for a speedy heating, pursuant to V I R Civ P 57

                                           LEGAL STANDARD
 1] 3    Guardian filed its present Motion for Reconsideration, asserting that the Court erred in
 denying its Motion to Dismiss in that Abdallah’s contractual connterclaims are invalid based on
 the terms ofthe Policy, and that Abdallah’s defamation counterclaim must fail as it does not allege
 facts showing publication of the alleged defamatory statements, an element required to show that
 he is entitled to relief for defamation

 1i 4    A party moving for reconsideration must demonstrate (1) an intervening change in
 controlling law, (2) the availability of new evidence, or (3) the need to correct clear error of law
or prevent manifest injustice ” Beachside Assocs LLC v Fishman, 53 V I 700, 715 (V I 2010),
see alsoVI R Civ P 6-4(b)

115     When ruling on Guardian’s Rule 12(b)(6) Motion to Dismiss, the Court was free to
consider the allegations of Abdailah’s Counterclaim, exhibits attached and matters of
                                                                                              public
record See Penman Benefit Gum Corp v White Como! Indus , 
998 F 2d 1192, 1196
 (3d
                                                                                                  Cir
1993) The Court could also have considered “documents whose contents are alleged
                                                                                 in the
complaint and whose authenticity no party questions, but which are not physically attached to the
pleading ’ See Pryor v NCAA 288 F 3d 548 560 (3d Cir 2002) (internal citations omitted)
                                                                                                  The
reasoning underlying this approach is particularly sound where the exhibit being considered is the
very document forming the basis of a claimant’s pleading Thus, “when ruling on
                                                                                       a motion to
dismiss, courts may consider undisputed documents relied upon by the claimant ” Groflv Cane
Bay Partners VI LLLP 
2017 WL 2709832
 at *1 (V I Super 2017)

1| 6    Here, Guardian included a copy ofthe Policy as an exhibit to its Complaint, and Abdallah
specificalIy referenced the terms of the Policy in his Counterclaim Because the contents of
                                                                                                  the
Policy are alleged in the Counterclaim and Guardian confirms the authenticity of the
                                                                                         Policy, its
terms could have been considered in the Court’s ruling on Guardian’s original Motion to
                                                                                           Dismiss
without converting it to a Rule 56 monon for summary judgment See V I R Civ R 12(d)
                                                                                                  The
Court now considers the Policy terms in evaluating Guardian’s present Motion challengi
                                                                                             ng the
sufficiency of Abdallah’s Counterciaim
  Guardian Insurance Companyv Ramzy Abdallah SX l9£V 110
  Memorandum Opinion and Order Granting Plaintiff’s Motion for Partial Reconsideration
  Page 3 of 7
                                                                               
2021 VI Super 20
 17       V I R Civ P 12(b)(6) permits a plaintiff to respond to a counterclaim by motion rather
 than through a responsive pleading if the basis for the motion is the counterclaimant’s “failure
                                                                                                    to
 state a claim upon which relief can be granted ” The Virgin Islands “is a notice
                                                                                             pleading
 jurisdiction,” and counterclaims must meet the nettee pleading standard of V I R Civ
                                                                            P 8(a)(2)
 to overcome a 12(b)(6) motion See Mills Wzllzams v Mapp 
67 VI 574
 585 86
                                                                          (VI 2017)
 (citations omitted) Under the notice pleading regime, counterclaims must present “a short and
 plain statement of the claim showing that the pleader is entitled to relief ” V I R Civ P 8(a)(2)

                                            DISCUSSION
 Defendant/Counter Plaintiff’s Counterclaim

 fl8      Abdallah’s Counterctaim rests on the assertion that the insurance contract is a “stated value
 insurance policy, declaring that the value ofthe vehicle is $36,000 ”' However, Guardian’s
                                                                                               Motion
 for Reconsideration recites the actual language ofthe insurance agreement, presented in its
                                                                                               Motion
 to Dismiss, which ctearly establishes that the Policy is not a “stated value” policy
                                                                                         but rather an
 “actual cash value” policy, subject to both depreciation and deductible 2

         You have purchased an insurance policy that insures your vehicle for its Actual
        Cash Value (defined as Replacement Cost less Depreciation) This means that at
        the time of loss your claimed loss will be evaluated on the basis of the cost of new
        parts, less reasonable depreciation, and less deductible
        As our insured, you have the option to purchase 3 Replacement Cost Policy
                                                                                  (cost
        new) at an additional cost Please consult your agent about your options
‘7 9    Because the Policy is an actual cash value policy agreement, by its terms           to which
Abdallah agreed      Abdallah is only entitled to the replacement cost of his vehicle at the time of
loss less depreciation and less deductible This is stipulated in the Personal Auto
                                                                                   Policy
Declarations page that reflects a premium paid for coverage for damage to your
                                                                                   Auto” as “Actual
Cash Value minus Deductible ”
1: 10   By Part D of the Policy, “Coverage for Damage to Your Auto,” Guardian
                                                                              agreed in the
“Insuring Agreement” 1A “We will pay for direct and accidental loss ‘to
                                                                        your covered auto’
  minus any applicable deductible shown in the Declarations ”


' Counterclaim fl 4
2 Guardian’s Mot Dismiss, at I l
  Guardtan Insurance Companyv Ramzy AbdaIIah SX l9-CV llO
  Memorandum Opinion and Order Granting Plaintiff’s Motion for Partial Reconsideration
  Page 4 of7
                                                                                  
2021 VI Super 20
 1] 11      The limits of Guardian’s payment for loss under Part D is set out in the section entitled
 “Limit of Liabiiity,” as follows
           A Our limit of liability for loss will be the lesser of the
             1 Actual cash value of the stolen or damaged property, or
            2 Amount necessary to repair or replace the property
           B An adjustment for depreciation and physical condition will be made in
           determining actual cash value at the time of loss 3
 fl 12      Policy based claims, Abdallah presents five separate claims within his Counterclaim 4 His
 claim for alleged violation of the VI Civil Rights Act (10 V I C §64) has been
                                                                                previously
 dismissed His claim for defamation is addressed below Each of Abdallah’s other three claims
 (for breach of contract, breach of the implied covenant of good faith and fair dealing,
                                                                                                  and for
 deceptive trade practices) is premised on the erroneous assertion that the Policy is a ‘ stated value’
 agreement requin'ng that Guardian is bound by the Policy to reimburse him for his loss in the
 amount of $36,000, the “stated value” of the vehicle

 1| 13     The breach of contract claim is based on Guardian’s “failure to pay the stated value ”5
                                                                                                       On
account of Guardian’s insistence on paying Abdallah’s claim based upon the
                                                                                       Policy terms, he
asserts that ‘Guardian has failed to perform the contract in good faith and has breached the implied
covenant of good faith and fair dealing ’6 Further Abdallah asserts that Guardia
                                                                                        n “engaged in a
deceptive trade practice by inter alia creating a stated value policy and refusing
                                                                                        to pay the stated
value in case of a total and complete loss as occurred here 7

1i 14      By each of these legal theories Abdallah claims that he is entitled to relief because
Guardian violated its obligation under the Policy by offering him $19,000 payment
                                                                                           for his stolen
auto, based upon its actual cash value rather than the $36,000 “stated value” to which he
                                                                                                  claims
the Policy entitled him The plain terms of the parties insurance agreement
                                                                                    make clear that
Guardian’s limit of liability on Abdallah’s loss is the actual cash value of the
                                                                                 vehicle at the time


3 Id Exhibit A
‘ The Counterelaim fails to conform to the requirements of V I R Civ P 8(2)
                                                                                in that it simply presents
difi’erent claims in consecutively numbered paragraphs without “separate designati
                                                                                  on of counts   for each
claim identified in the pleading ”
5 Counterciaim 1}]?
a 1d 718
7 Id m9
 Guardmn Insurance ( ompany v Ramzy AbdaIIah 8X 19 CV 110
 Memorandum Opinion and Order Granting Plaintiff’s Motion for Partial Reconsideration
 Page 5 of 7
                                                                                     202R VI Super 20

 of its loss Accordingly, all of Abdallah’s contractual claims based upon an erroneous assertion of
 the Policy tenns cannot survive Guardian’s Mouon for Reconsideration will be granted as to these
 counts, each of which will be dismissed with prejudice a
 {I 15   Defamation Abdallah timber alleges that Guardian falsely stated that Abdallah
 orchestrated the theft of his own vehicle and engaged in insurance fraud, commuting defamation
 and defamation per sag However, these communicanons are only alleged to have occurred
 between the parties—«Guardian through its agent, adjuster or attorney and Abdallah One of the
 necessary elements ofdefamation is ‘an unprivileged publication to a third party ” Joseph v Datly
 News Pub] g Co Inc , 
57 VI 566 586
 (V I 2012) (citing RESTATEMENT (SECOND) OF Toms
 §558(b)) Publication means the “communication intentionally or by negligent act to one other
 than the person defamed’ Id (citing RESTATBMENT (SECOND) 01-" Tons § 577)

7} l6    Abdallah does not allege publication of the purported defamatory statements to anyone
other than to Abdallah himself '0 Although Abdallah s pleading alleges no publication of the
alleged defamatory statements to anyone other than Abdallah himself, a claim is made that
Abdallah’s attorney warned Guardian’s attorney concerning defamation “Guardian Insurance
through Mr Foumier then began to accuse Mr Abdullah of theft and Insurance fraud with
absolutely no proofwhatsoever Guardian’s counsel thereafter engaged in the conduct and quickly
refrained after counsel reminded her that she was engaging in defamation per se             ””
11 17    Even if a claim were presented that Guardian’s representatives made defamatory
statements concerning Abdallah to Abdallah’s counsel, those communications must be seen to be
conditiOnally privileged “An occasion makes a publication conditionally privileged if the
circmnstances induce a correct or reasonable belief that (a) there is information that affects
                                                                                                           a


' In its “Wherefore” clause, the Counterclaim also seeks damages for the tort of “insurance bad faith,”
                                                                                                          not
elsewhere mentioned in the Counterclaim Because Abdallah’s pleading does not set out “a
                                                                                              short and plain
statement of the claim showing that the pleader is entitled to relief" with reference to such a
                                                                                                claim, to the
extent that such a claim is alleged, it also subject to dismissal See V l R Civ P 8(a)(2)
9 Counterclaim ‘11 ll, 20
'° “Guardian thereafter began to accuse Abdullah of orchestrating the thefi of his vehicle;
                                                                                                “Abdullah
further claims that Guardian has defamed him and engaged in defamation per se by suggesting
                                                                                                   that he
orchestrated the theft of his vehicle and engaged in insurance fraud ” Counterelaim 1|? l l;
                                                                                             20
” Answer to Complaint and Counterclaim, introduction, at l
  Guardtm Insurance Company v Ramzy AbdaIIah SX 19 CV 110
  Memorandum Opinion and Order Granting Plaintifi’s Motion for Partial Reconsideration
  Page 6 of '7
                                                                                          202! VI Super 20
  sufficiently important interest ofthe publisher, and (b) the recipient’s knowledge
                                                                                               ofthe defamatory
  matter will be of service in the lawful protection of the interest ”'2
  1] 18     Communications between Guardlan’s representatives and Abdallah and his attorney
                                                                                                             in the
  context of seeking a resolution of Abdallah’s insurance claim concerning the vehicle
                                                                                      he reported
  stolen clearly affect an important interest of Guardian, the alleged publisher of the
                                                                                        offendmg
 defamatory statements (and also affect an important interest of Ahdallah)
                                                                            In that context,
 knowledge of the information conveyed by Guardian’s lepresentatives to Abdalla
                                                                                h’s attorney
 would benefit the lawfiJl protection of Guardian’s interest in seeking to
                                                                         resolve Abdallah’s
 insurance claim Notwithstanding the foregoing, it is unnecessary to determine
                                                                               whether Guardian’s
 representatives’ statements were subject to privilege in the commumcations alleged,
                                                                                     as Abdallah’s
 pleading does not claim that the alleged defamatory statements were ever
                                                                              published to a third
 party :3

 1] l9      Defmnation and defamation per se are legal conclusions that, absent facts, are
                                                                                                     not entitled
 to the presumption of truth Abdallah’s Counterclaim fails to allege the necessa
                                                                                                  ry element of
 publication with regard to his defamation claims As such, Abdallah has failed
                                                                                             to set forth a short
 and plain statement of the claims showing that he is entitled to relief required by V
                                                                                                    I R Civ P
 8(a)(2), and Guardian is entitled to the dismissal ofthat claim for Abdallah’s
                                                                                         failure to state a claim
upon which relief can be granted

1| 20     On the basis of the foregoing, all the claims set out in Abdallah’s Counterclaim
                                                                                                     fail to state
a claim upon which relief can be granted, and are therefore insufficient to survive
                                                                                                     Guardian’s
Motion to Dismiss Defendant’s Counterclaim pursuant to V1 R Civ
                                                                      P 12(b)(6) The Court
reconsiders its December 18, 2020, Order, and Abdallah’s Counterclaim
                                                                      will be dismissed in its
entirety




'1 RESTATEMENT (SECOND) OF Toms § 594
'3 Similarly, because the Counterclaim includes no allegations of publicati
                                                                                  on, other potential claims of
privilege relating to the attorney client relationship or to matters in litigation
                                                                                   , or threatened litigation, are
not addressed
 Guardian Insurance Company v RamzyAbdaIIah 8X 19 CV ll0
 Memorandum Opinion and Order Granting Plaintiff’s Motion for Partial Reconsideration
 Page ‘7 of7
                                                                                    
2021 VI Super 20

           Accordingly, it is hereby
           ORDERED that Guardian’s Motion for Partial Reconsideration of the Court’s Decembe
                                                                                                           r
 18, 2020 Order Denying in Part Plaintiff’s Motion to Dismiss Defendant’s Counterclaim
                                                                                                          is
 GRANTED It is further

        ORDERED that Abdallah’s Counterclaim is DISMISSED with prejudice as to all claims
It is further

        ORDERED that this matter will come on for hearing on Plaintiff’s Complaint seeking
Declaratory Judgment and Specific Performance, pursuant to V I R Civ P 57, via
                                                                              Zoom, on
Monday, March 29, 2021 at 9 00 a m

        The parties will strictly adhere to the following remote hearing protocols
        0     Not less than 7 days prior to the hearing, each party shall file and serve upon the other
              party its list of witnesses, and shall file and serve copies ofall exhibits to be introduce
                                                                                                          d,
              which shall be pre marked
        0     All witnesses who will testify must appear on camera, and any other person in
                                                                                               the
             room where the witness testifies shall also be visible on camera Witnesses who are not
             on camera will not be permitted to testify
       o     All participants, including attorneys, panics, party representatives and witnesses
                                                                                                      must
             have use of a good wi f1 connection, with clear audio and video transmission
       0     Witnesses will be called and will be permitted in the virtual courtroom only while
                                                                                                they
             are testifying Witnesses shall not hold notes or have paperwork or any docmnentation
             in front of them while testifying
       0     Any party objecting to any witness or exhibit, or to any of these protocols may file
                                                                                                  an
             appropriate motion no later than March 25, 2021 It is further

       ORDERED that a copy of this Order be served on the appropriate parties


DATED February/ Q 2021                                                             X
                                                          DOUGLAS A BRADY J JDGE
ATTBST
TAMARA CHARLES
Clerk of the Co

By M
           curt lerk Supervisor
        2/1 9/202 1