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Subrogation claims rely on fault, and insurance companies can only file claims against those they can prove are liable for property damage. If you can demonstrate that you are not liable for the property damage, the insurance company will have no grounds for their claim, and you will not have to pay it.
If you were at-fault in the accident and are uninsured, then you may receive a subrogation letter from the other driver's insurance company seeking reimbursement directly from you. There is no requirement to respond, but it can be in your best interests to reply.
Negotiate the claim. If you and your lawyer are unable to stop the subrogation claim altogether, it is possible to negotiate. Most insurance companies are willing to negotiate because they want to settle claims quickly and get their money.
As to the format, a subrogation letter should include: Letter creation date. The name of the insured and the name of the at-fault party. The sum paid to the insured. Summary of the damages. Request for the policy number of the recipient. Request to contact the insurance company and contact details.
One example of subrogation is when an insured driver's car is totaled through the fault of another driver. The insurance carrier reimburses the covered driver under the terms of the policy and then pursues legal action against the driver at fault.