AGG Partner Heather Smith Michael authored two Case Notes for the American Bar Association Section of Litigation, titled “Tender of Policy Limits Not a Defense to Action to Enforce Hospital Lien” and “Claims for Breach of Contract and Bad Faith are Properly Bifurcated.” The former refers to the case Southern General Insurance Co. v. Wellstar Health Systems, Inc., No. A11A2065, 2012 Ga. App. LEXIS 306 (Ga. Ct. App. Mar. 20, 2012), involved an insurer’s obligations under an automobile liability policy when faced with both a claim by an injured party and a hospital lien. The latter involves Saye v. Provident Life & Accident Insurance Company, 714 S.E.2d 614 (Ga. Ct. App. 2011) in which the insured sued Provident for breach of contract and bad faith based on its failure to pay continuing benefits under a disability insurance policy.