PLAINTIFF’S SECOND AMENDED COMPLAINT Page 1 

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

HILLTOP HOLDINGS INC. § 

 § 

Plaintiffs, § 

v. § CIVIL ACTION NO. 3:22-CV-907-S

 § 

AIG SPECIALTY INSURANCE COMPANY § 

 § 

Defendant. § 

PLAINTIFF’S SECOND AMENDED COMPLAINT

Plaintiff, Hilltop Holdings Inc. (“Hilltop”) files this Second Amended Complaint against 

Defendant AIG Specialty Insurance Company (“AIG”) as follows: 

I. INTRODUCTION

1. Hilltop’s subsidiary, PlainsCapital Bank1, currently is defending claims of fraud, 

misrepresentation and alleged violations of certain Louisiana statutes in two different lawsuits

titled PlainsCapital Bank v. FR III Funding, et al., Cause No. DC-16-07601, pending in the 134th 

District Court of Dallas County (“Guarantors Lawsuit”) and Byrum W. Teekell, et al v. David D. 

deBerardinis et al., No. 599,295 A, pending in the First Judicial District Court of Caddo Parish, 

Louisiana (“Teekell Lawsuit”). 

2. Hilltop timely made a claim for defense and indemnity related to the Guarantors 

Lawsuit and Teekell Lawsuit under its insurance policy issued by AIG. AIG refuses to pay for 

covered defense costs incurred by Hilltop. 

3. Hilltop sues AIG for breach of contract to recover the unpaid defense expenses and 

1 PlainsCapital Bank is a wholly owned subsidiary of PlainsCapital Corporation. On November 30, 2012, Hilltop 

Holdings Inc. acquired PlainsCapital Corporation and all of its subsidiaries, including PlainsCapital Bank.

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costs it has paid, as well as to recover its reasonable and necessary attorneys’ fees, statutory 

damages, and interest.

II. PARTIES 

4. Plaintiff Hilltop Holdings Inc. is a Maryland Corporation with its principal place of 

business in Dallas County, Texas.

5. Defendant AIG Specialty Insurance Company is a surplus lines carrier eligible to 

engage in business in Texas. It is also an Illinois corporation with its principal place of business in 

Illinois. AIG has contractually consented to the jurisdiction of Texas courts in this action. AIG has 

previously made an appearance in this case.

6. AIG is authorized to conduct business in the State of Texas.

III. JURISDICTION 

7. Plaintiff and Defendant are citizens of different states and the amount in 

controversy exceeds $75,000.00, exclusive of interest and costs. This Court therefore has 

jurisdiction over the lawsuit pursuant to 28 U.S.C. §1332(a).

IV. VENUE 

8. Venue is proper in this Court under 28 U.S.C. §1391 because a substantial part of 

the events or omissions giving rise to Hilltop’s claims occurred in this district.

V. CONDITIONS PRECEDENT

9. All conditions precedent set forth in the applicable insurance contracts have been 

performed or have occurred, as required by Fed. R. Civ. P. 9(c).

VI. POLICY AT ISSUE

10. AIG issued Bankers Professional Edge for Portfolio Select Policy No. 01-188-84-66

(the “Policy”) to Hilltop.

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11. The Policy provides coverage up to $10,000,000 for the Bankers Edge Bankers 

Professional Liability Coverage Section (the “BPL Coverage Section”). 

12. The Policy has a Policy Period of February 28, 2016, to February 28, 2017. 

13. Hilltop paid a premium of $389,400 for the Policy. 

14. The BPL Coverage Section provides coverage for Loss of any Insured that arises 

from any Claim first made against such Insured during the Policy Period for any Wrongful Act of 

the Insured in the rendering of or failure to render Professional Services. Loss includes, but is not 

limited to, Defense Costs.

15. The BPL Coverage Section contains the following applicable definitions:

Insured means “(1) any Insured Person; or (2) an Organization.” 

Insured Person means “any past, present or future partner, director, officer, 

managing member, board of managers, trustee, committee member or 

employee of an Organization, or foreign equivalent titles of an 

Organization, but in all cases only while acting in the scope of his or her 

duties as such.”

Organization means “(1) the Named Entity; and (2) each Subsidiary.”

Subsidiary means “(1) any for-profit entity which the Named Entity has or 

had Management Control on or before the Inception Date of this policy 

either directly or indirectly through one or more of its other Subsidiaries; 

and (2) any not-for-profit entity sponsored exclusively by an Organization. 

A for-profit entity ceases to be a Subsidiary when the Named Entity no 

longer maintains Management control of such entity either directly or 

indirectly through one or more of its Subsidiaries. A not-for-profit entity 

ceases to be a Subsidiary when such entity is no longer sponsored 

exclusively by an Organization.”

16. The BPL Coverage Section of the Policy defines Defense Costs as:

“... reasonable and necessary fees, costs and expenses consented to by the 

Insurer (including premiums for any appeal bond, attachment bond or 

similar bond arising out of a covered judgment, but without any obligation 

to apply for or furnish any such bond) resulting solely from the 

investigation, adjustment, defense and appeal of a Claim against the 

Insureds. Defense Costs shall not include the compensation of any Insured 

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Person.”

17. The BPL Coverage Section is subject to a self-insured retention of $750,000

(“Retention”).

18. The Policy requires AIG to advance covered Defense Cost, in excess of the 

Retention, on a current basis, but no later than ninety (90) days after AIG receives the itemized bills.

VII. FACTUAL ALLEGATIONS

Underlying Lawsuits

19. On June 23, 2016, PlainsCapital Bank (“PCB”) initiated the Guarantors Lawsuit

against David deBerardinis (“deBerardinis”), FR III Funding, LLC (“FR III”), a deBerardinis 

owned entity, and several individuals including Jerry Webb, Craig Webb, Patrick Mulligan, and 

Stephen Herbel (collectively, the “Guarantors”) to recover amounts owed under a loan and to 

enforce certain guaranty agreements signed by the Guarantors.

20. On July 25, 2016, the Guarantors filed their answer and several affirmative defenses 

including fraud, negligence, and misrepresentation. 

21. On May 19, 2017, the Guarantors filed counterclaims against PCB alleging PCB 

fraudulently induced them into signing the guaranty agreements at issue and that PCB failed to 

perform sufficient due diligence for the loan in question. Specifically, the Guarantors assert claims 

for fraud by omission, fraud by non-disclosure, aiding and abetting, fraudulent inducement, 

negligent misrepresentation, and negligent misrepresentation by omission. PCB denies these 

allegations.

22. On August 30, 2019, PCB and Sam Wooten, a former employee of PCB, were 

named as defendants in the Teekell Lawsuit. Plaintiffs in the Teekell Lawsuit assert that 

deBerardinis orchestrated a fraudulent scheme to defraud Plaintiffs and that PCB, as well as Sam 

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Wooten, assisted deBerardinis in furthering deBerardinis’ illegal enterprise. Specifically, Plaintiffs 

assert claims for violations of the Louisiana Racketeering Act and Louisiana Securities Laws and

fraudulent misrepresentation. PCB also denies the allegations in the Teekell Lawsuit.

23. PCB and Sam Wooten are Insureds as defined by the BPL Coverage Section of the 

Policy.

Claims Handling 

24. On August 2, 2016, a Notice of Claim was submitted to AIG for the Guarantors 

Lawsuit. Shortly thereafter, AIG hired coverage counsel to assist in the coverage analysis and 

collaborate with the adjuster to draft coverage correspondence.

25. AIG acknowledged receipt of the claim for the Guarantors Lawsuit by letter dated 

November 15, 2016. AIG states in the letter that it has reviewed a copy of the Policy. AIG goes 

on to say: “The BPL Coverage Section is not implicated by affirmative claims such as those 

asserted by the Bank in the Action. Moreover, the Counterclaims are brought against the Borrower 

and Mr. deBerardinis, neither of whom is an Insured under the Policy. Accordingly, there has not 

been a Claim made against an Insured in this matter, and the BPL Coverage Section is not currently 

implicated by this matter.” Nevertheless, AIG agreed to accept the notice as a notice of 

circumstances that may subsequently give rise to a claim. These statements appear in the section 

of the letter labeled “Coverage Analysis.” In the letter, AIG does not quote the definition of 

“Defense Costs” or any portion of it.

26. On May 24, 2017, five days after it was filed, Hilltop provided AIG with a copy of 

the first pleading containing the Guarantors’ counterclaims and requested a coverage 

determination from AIG. 

27. On June 16, 2017, AIG acknowledged receipt of the Guarantors’ counterclaims

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against PCB and supplemented its November 15, 2016 letter. In its “Supplemental Coverage 

Analysis,” AIG accepted the counterclaims as a claim under the Policy, and “reiterate[d]” that 

“any legal fees and costs or other amounts incurred in the prosecution of the Bank’s claims in the 

Action are not covered . . . .” With respect to defense of the counterclaims, those fees and costs 

will “have to be allocated . . . ,” according to AIG. But AIG did not explain how the allocation 

will work, who will do it, or when it will occur. Although AIG references “Defense Costs,” it did

not quote the language or advise its insureds that it intended to use the words “resulting solely” to 

deny all hybrid or mixed attorneys’ fees and expenses. Apparently, unless the word “counterclaim” 

appeared in the billing entry, AIG did not intend to permit reimbursement, but it did not share this 

undisclosed requirement with its insureds. In addition, AIG did not disclose that that it sought to 

pay only “reasonable and necessary” attorneys’ fees and expenses. Based on its later course of 

conduct and failure to reserve rights on this issue, among other things, Hilltop considers the issue 

of reasonable and necessary, as applied to the underlying legal fees and expenses, waived.

28. On September 19, 2017, AIG’s coverage counsel and Hilltop’s defense counsel in 

the Guarantors Lawsuit participated in a telephone conference to discuss the status of the 

counterclaims. 

29. On January 23, 2018, Hilltop’s defense counsel in the Guarantors Lawsuit provided 

AIG’s coverage counsel with an update on the counterclaims and status of the Guarantors Lawsuit.

30. On March 29, 2018, and March 30, 2018, Hilltop’s defense counsel corresponded 

with AIG’s coverage counsel regarding the status of the counterclaims.

31. On July 12, 2018, Hilltop’s defense counsel provided AIG with an update on the 

counterclaims and status of the Guarantors Lawsuit. 

32. On October 10, 2018, Hilltop’s defense counsel updated AIG’s coverage counsel 

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on the Guarantors Lawsuit including the counterclaims. 

33. In January 2019, Hilltop informed AIG that Hilltop had incurred between $5-6 

million in defense costs to date. Further, Hilltop proposed that the parties come to an agreement 

as to the allocation and payment of covered Defense Costs. AIG did not respond. 

34. In March 2019, again, Hilltop again attempted to secure an agreement with AIG 

regarding payment of covered Defense Costs, but AIG rejected Hilltop’s proposal and failed to 

present a counteroffer.

35. Hilltop continued to push for an agreement with AIG. On March 28, 2019, April 3, 

2019, and April 25, 2019, Hilltop requested an update from AIG regarding its determination of 

payment of covered Defense Costs, but AIG continued to ignore Hilltop’s requests.

36. On November 7, 2019, AIG acknowledged receipt of the first pleading naming PCB 

and Sam Wooten in the Teekell Lawsuit and confirmed it constituted a claim under the Policy.

37. On November 22, 2019, Hilltop provided AIG with attorneys’ fees invoices 

reflecting the Defense Costs incurred by Hilltop for both the Guarantors Lawsuit as well as the 

Teekell Lawsuit.

38. On July 23, 2021, over a year and eight months later, AIG provided its initial 

analysis of the attorneys’ fees invoices. 

39. Despite having sufficient time to conduct a thorough evaluation, AIG’s analysis of 

the attorneys’ fees invoices to determine covered Defense Costs included a simple word search of 

each attorneys’ fee invoice for the word “counterclaim.” As discussed above, AIG never informed 

Hilltop or its attorneys that such a word would be required to seek reimbursement. In fact, AIG 

admits that it did not tell defense counsel to use the word “counterclaim” in any fee entry related 

to defense of the counterclaims. AIG’s investigation was, and continues to be, both inadequate and 

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untimely. AIG indicated it would recognize $535,423.61 in covered Defense Costs related to the 

Guarantors Lawsuit and $203,440.59 in covered Defense Costs related to the Teekell Lawsuit for 

a total of $738,864.20, an amount conveniently within the Retention. 

40. Despite all of the communications over the preceding five years, AIG never 

explained to its insureds that it intended to use the language “resulting solely” from the definition 

of Defense Costs to deny reimbursement of all hybrid or mixed fees and expenses, and it never 

explained to its insured how it would use that language. Over the same period of time, it never 

reserved its rights as to any limitations in the definition of Defense Costs.

41. AIG admits that in denying all hybrid or mixed attorneys’ fees and expenses, it is 

depriving Hilltop of the reimbursement of some fees and expenses attributable to defense of the 

counterclaims, but AIG insists that its coverage interpretation is correct. Hilltop disagrees, 

demonstrating that under Texas law, further allocation is both appropriate and possible. Although 

Hilltop believes that the definition of Defense Costs is unambiguous, if the Court disagrees, Hilltop

hereby pleads ambiguity in the alternative.

42. As a result of AIG’s insufficient analysis of the attorneys’ fees invoices, Hilltop 

was forced to conduct its own review. Contrary to AIG’s cursory investigation, Hilltop’s analysis 

of the attorneys’ fees invoices incorporated a line-by-line review of each entry of each invoice as 

well as extensive evaluation of filed pleadings and exchanged discovery to determine whether the 

work reflected in each entry did in fact go towards the defense of the counterclaims.

43. On October 27, 2021, Hilltop provided its initial analysis of the attorneys’ fees 

invoices to AIG. Hilltop’s independent review of the attorneys’ fees invoices revealed that Hilltop 

had incurred millions in covered Defense Costs, well over the $750,000 Retention.

44. Hilltop continues to incur attorneys’ fees in the Guarantors lawsuit, and as of May 

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31, 2023, Hilltop contends that it has incurred a total of $7,023,365.67 in covered Defense Costs.

45. AIG now admits that the Retention has been met. Nevertheless, AIG has recognized

only $314,336.15 in covered Defense Costs, made in three payments to Hilltop. The first payment 

of $109,077.22 was made on February 15, 2023. The second payment of $179,428.99 was made 

on April 12, 2023. The third payment of $25,829.94 was made on September 1, 2023. At least one 

of these payments was not made within 90 days of receiving the itemized invoices. According to 

AIG, these payments include covered Defense Costs from both the Guarantors Lawsuit and the 

Teekell Lawsuit. In fact, AIG has paid all outstanding Defense Costs in the Teekell Lawsuit and 

denied the vast majority of the Defense Costs in the Guarantors Lawsuit, even though much of the 

legal work was identical. AIG never contested the reasonableness or necessity of these legal fees 

and expenses before issuing these payments.

46. Despite receiving Hilltop’s calculations based on a more reliable and thorough 

investigation, and despite the fact that Hilltop has continued to incur significant legal fees and 

expenses defending these claims, AIG continues to unreasonably delay and/or refuse payment of 

covered Defense Costs. Meanwhile, Hilltop has paid the total amount of attorneys’ fees and costs 

incurred in the Guarantors Lawsuit and in the Teekell Lawsuit.

CAUSES OF ACTION

COUNT I 

BREACH OF CONTRACT

47. Hilltop incorporates each and every allegation set forth above. 

48. The Policy is a valid and enforceable contract. 

49. Hilltop has at all times fully performed its obligations under the Policy and paid the 

required premiums.

50. AIG committed a material breach of the Policy by failing and refusing to pay for 

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the covered Defense Costs.

51. In addition, or in the alternative, AIG committed a material breach of the Policy by 

failing to advance Defense Costs no later than ninety days after receiving itemized bills.

52. As a result of these material breaches, Hilltop has been damaged.

COUNT II

VIOLATIONS OF TEXAS PROMPT PAY OF CLAIMS ACT

53. Hilltop incorporates each and every allegation set forth above. 

54. Under the Texas Insurance Code, AIG had a duty to investigate and pay Hilltop’s

claims in a timely manner. See Tex. Ins. Code Ann. §§ 542.051-.061.

55. AIG violated Section 542 of the Texas Insurance Code by not timely: (1) accepting 

or rejecting the claim [542.056(a)]; (2) stating the reasons for any denial [542.056(c)]; and (3) 

paying the claim within 60 days after receiving all items, statements and forms reasonably 

requested [542.058(a)].

56. In addition, if Hilltop establishes a breach of the Policy, Hilltop is entitled to Texas 

Prompt Pay damages pursuant to Section 542.060 and 542.061.

57. As a result, Hilltop has been damaged and continues to be damaged by AIG’s 

conduct. 

COUNT III

UNFAIR OR DECEPTIVE INSURANCE PRACTICES

- VIOLATIONS OF TEX. INS. CODE 541

58. Hilltop incorporates each and every allegation set forth above.

59. AIG’S conduct, as more fully described above, constitutes a violation of Chapter 

541 of the Texas Insurance Code. 

60. AIG is contractually obligated under the Policy to pay the covered Defense Costs, 

subject only to the Retention and applicable Policy limits. 

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61. AIG has engaged in a pattern of unfair and deceptive conduct aimed at delaying, 

minimizing, and avoiding its obligations to pay the covered Defense Costs incurred by Hilltop, 

and depriving Hilltop of the benefits and protection of the insurance coverage for which substantial 

premiums were paid.

62. AIG’s conduct constitutes a violation of Chapter 541 of the Texas Insurance Code 

by engaging in one or more of the following prohibited acts:

a. misrepresenting to Hilltop a material fact or policy provision relating to

coverage at issue [541.060(a)(1)];

b. failing to attempt in good faith to effectuate a prompt, fair and equitable 

settlement of (A) a claim with respect to which AIG’s liability has become 

reasonable clear [541.060(a)(2)]; 

c. failing to promptly provide Hilltop a reasonable explanation of the basis in the 

policy, in relation to facts or applicable law, for AIG’s denial of the majority of 

the Defense Costs in the Guarantors Lawsuit [541.060(a)(3)];

d. failing within a reasonable time to (A) affirm or deny coverage [541.060(a)(4)];

e. refusing to pay a claim without conducting a reasonable investigation with 

respect to the claim [541.060(a)(7)];

f. misrepresenting an insurance policy by: (1) making an untrue statement of 

material fact [541.061(1)]; (2) failing to state a material fact necessary to make 

other statements not misleading, considering the circumstances under which the 

statements were made [541.061(2)]; (3) making a statement in a manner that 

would mislead a reasonably prudent person to a false conclusion of a material 

fact [541.061(3)]; and (4) failing to disclose a matter required by law to be 

disclosed [541.061(5)].

63. As a result of the foregoing violations of chapter 541 of the Texas Insurance Code, 

Hilltop has suffered substantial damages recoverable pursuant to Section 541.152(a) of the Texas 

Insurance Code.

64. AIG’s unfair and deceptive conduct, as described above, has been undertaken 

knowingly, and is not the result of an isolated mistake of fact or law, honest error of judgment, or 

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negligent act. AIG’s conduct reflects a concerted and deliberate effort to mislead Hilltop regarding 

payment of Defense Costs and deprive Hilltop of the contractual benefits for which it paid 

substantial premiums. AIG’s misconduct warrants an award of treble damages for the purpose of 

deterrence and/or punishment pursuant to Tex. Ins. Code § 541.152(b).

COUNT IV

ATTORNEYS’ FEES AND STATUTORY INTEREST

65. Hilltop incorporates each and every allegation set forth above.

66. Hilltop was forced to engage legal counsel in order to redress its losses. Hilltop is 

entitled to recover its attorneys’ fees arising out of these coverage disputes under the Texas Civil 

Practice & Remedies Code. See Tex. Civ. Prac. & Rem. Code § 38.001(8) (statutory basis for 

recovery of attorneys’ fees in breach of contract case); Tex. Ins. Code Ann. § 541.152 (statutory 

basis for recovery of attorneys’ fees for violation of chapter 541 of the Texas Insurance Code); 

and Tex. Ins. Code Ann. § 542.060 (statutory basis for recovery of attorneys’ fees for violation of

Texas Prompt Payment of Claims Act). 

67. Additionally, due to AIG’s violations of the Texas Prompt Payment of Claims Act, 

AIG is liable for the interest on the amount of Hilltop’s claim at the rate of 18% per year as 

damages. Tex. Ins. Code Ann. § 542.060.

68. As is customary in the Northern District of Texas, Hilltop anticipates that the issue 

of attorneys’ fees, if applicable, will be decided by the Court on motion after trial pursuant to Rule 

54(d)(2)(A) of the Federal Rules of Civil Procedure.

VIII. JURY DEMAND

69. Hilltop hereby demands a trial by jury.

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IX. RELIEF REQUESTED

WHEREFORE, PREMISES CONSIDERED, Hilltop respectfully requests judgment 

against AIG as follows: 

a. an award of actual damages against AIG for AIG’s breach of the Policy;

b. an award of actual damages against AIG for AIG’s violations of chapter 541 and 

542 of the Texas Insurance Code;

c. interest at a rate of 18% per annum pursuant to Tex. Ins. Code § 542.060; 

d. treble damages, pursuant to Tex. Ins. Code § 541.152; 

e. attorneys’ fees incurred herein plus interest on said fees at the highest rate allowed 

by law from the date of entry of judgment until paid in full; 

f. total costs of the suit herein including pre-judgment and post-judgment interest at 

the highest rate allowed by law; and

g. for such other and further relief at law and in equity as the Court may deem 

appropriate. 

Respectfully submitted,

/s/Beverly B. Godbey

Beverly B. Godbey 

State Bar No. 02068600 

beverly@amystewartlaw.com

Meggan Burchfield 

State Bar No. 24038753 

meggan@amystewartlaw.com

Beth Kressel Itkin

State Bar No. 24118435 

beth@amystewartlaw.com

AMY STEWART PC

5307 E. Mockingbird Lane, Suite 425 

Dallas, Texas 75206 

Telephone: (214) 233-7076 

Facsimile: (214) 975-2806 

ATTORNEYS FOR PLAINTIFF

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CERTIFICATE OF SERVICE

I do hereby certify that on December 1, 2023, a true and correct copy of the foregoing 

Plaintiff’s Second Amended Complaint was served by electronic transmission via the Court’s 

CM/ECF system upon all parties registered to receive electronic notice in this case.

By: /s/Beverly Godbey

 Beverly Godbey 

4891-4424-9408, v. 2

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