In a case which represents troubling precedent to the insurance industry, the United States District Court for the Eastern District of Pennsylvania in Atiyeh v. Liberty Mutual Fire Insurance Company, 2002 WL 88918 (E.D. Pa. Jan. 8, 2002) seemingly created a new category of bad faith liability in Pennsylvania by holding that a suggestive letter sent to the carrier's expert may be indicia of the carrier's bad faith.