1.) Miller v. Nationwide Insurance, 112 N.C. App 295 "These allegations of plaintiffs complaint are sufficient to support an award of damages, including punitive damages, based upon a bad faith refusal to pay plaintiff's claim." 112 N.C. App. at 306 2.) Lovell v. Nationwide Insurance, 108 N.C. App. 416, 424 “For example in Lovell, aggravation was demonstrated by Nationwide's failure to conduct a timely investigation of a claim under the liability coverage and delay in paying med pay in order to affect a lower settlement of the pending liability claim.”  108 N.C. App. 416, 42 3.) Smith v. Nationwide Insurance, 96 N.C. App 215,385 “The Smith court held that the plaintiff's allegations of three violations of N.C. Gen. Stat. §58-54.4(11) satisfied the aggravation element of the bad faith tort. Additional facts alleged in support of the aggravation element included a five month passage of time between the adjuster's initial contact and issuance of a claim check; extended negotiations with little progress towards resolution; and large differences between plaintiff's estimates and Nationwide's estimates. The Smith court also endorsed the holding from Payne, supra, that aggravated conduct could be shown by a pattern of excuses raised by an insurance company for refusing to pay a claim.” 96 N.C. App 215,385 4.) Romano v. Nationwide Insurance Company, 435 PA. Super. 545, 646 A.2d 1228(1994). "Bad faith" on part of insurer is any frivolous or unfounded refusal to pay proceeds of a policy; it is not necessary that such refusal be fraudulent. For purposes of an action against an insurer for failure to pay a claim, such conduct imports a dishonest purpose and means a breach of a known duty (i.e. good faith and fair dealing), through some motive of self-interest or ill will; mere negligence or bad judgment is not bad faith.