Mealey's (October 19, 2017, 8:14 AM EDT) -- ORLANDO, Fla. — A Florida federal judge on Oct. 17 dismissed an insured’s bad faith counterclaim against an auto insurer because under Florida law, a bad faith claim cannot be alleged until a determination of the insured's damages has been made (Owners Insurance Co. v. Michael Berke, No. 17-1505, M.D. Fla., 2017 U.S. Dist. LEXIS 171454)....