James G. Lowe, M.D. v. Bernard Audet

CourtNew Jersey Superior Court Appellate Division
DecidedJune 24, 2025
DocketA-4093-23
StatusUnpublished

This text of James G. Lowe, M.D. v. Bernard Audet (James G. Lowe, M.D. v. Bernard Audet) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James G. Lowe, M.D. v. Bernard Audet, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4093-23

JAMES G. LOWE, M.D.,

Plaintiff-Appellant,

v.

BERNARD AUDET, RICHARD LAVER, and THE CREATIVE FINANCIAL GROUP, LTD.,

Defendants-Respondents. ___________________________

Argued February 4, 2025 – Decided June 24, 2025

Before Judges Gooden Brown and Vanek.

On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Camden County, Docket No. L-0633-24.

Stephen J. DeFeo argued the cause for appellant (Brown & Connery, LLP, attorneys; Stephen J. DeFeo, Kathleen E. Dohn, and Taylor L. Johnson, on the briefs). Jared K. Levy argued the cause for respondent Richard Laver (Wood, Smith, Henning & Berman, LLP, attorneys; Jared K. Levy, on the brief).

Barry R. Temkin argued the cause for respondents Bernard Audet and The Creative Financial Group, Ltd. (Mound Cotton Wollan & Greengrass LLP, attorneys; Katharine Anne Lechleitner, Barry R. Temkin, and Kate E. DiGeronimo, on the brief).

Robert H. Solomon argued the cause for amicus curiae New Jersey Association for Justice (Nagel Rice, LLP, attorneys; Bruce H. Nagel, on the brief).

PER CURIAM

By leave granted, plaintiff James G. Lowe, M.D., appeals from Law

Division orders entered on July 19, 2024, granting motions to dismiss his claims

under the Consumer Fraud Act (CFA), N.J.S.A. 56:8-1 to -210, against

defendant insurance brokers Richard Laver and Bernard Audet and defendant

The Creative Financial Group, Ltd. (CFG) (collectively defendants). We

granted the New Jersey Association for Justice's (NJAJ) application to

participate as amicus in support of plaintiff's position. Having considered the

record and the governing principles, we affirm the dismissal of plaintiff's CFA

claims.

A-4093-23 2 I.

We glean these facts from plaintiff's complaint, accepting as true the facts

alleged therein. Lemelledo v. Beneficial Mgmt. Corp. of Am., 150 N.J. 255,

263 (1997). Through defendants, plaintiff, a neurosurgeon, procured four

MetLife insurance policies: (1) an individual disability income (IDI) policy

providing a $10,000 monthly benefit until age sixty-five, effective December 1,

2003; (2) another IDI policy providing a $10,000 monthly benefit until age

sixty-seven, effective June 1, 2016; (3) a business overhead expense (BOE)

policy with a $30,000 monthly benefit and a twenty-four-month maximum

benefit period, effective February 17, 2009; and (4) another BOE policy with a

$20,000 monthly benefit and a twelve-month maximum benefit period, also

effective February 17, 2009.

The IDI policies covered plaintiff individually, while the BOE policies

covered his surgical practice, Lowe Greenwood Zerbo Spinal Associates, P.A.

(LGZ), of which he was a fifty-percent co-owner. Plaintiff alleged all four

policies "contain[ed] a waiver of premiums benefit, which states 'we will waive

any premium that becomes due while you remain disabled' and 'your policy and

its benefits will continue as if the premium had been paid.'"1

1 The insurance policies are not part of the record. A-4093-23 3 In purchasing the policies, plaintiff alleged that he relied on his two-

decades-long "special relationship" with defendants. Plaintiff's business

relationship with CFG commenced in 2002. Audet and Laver, described as "a

disability insurance expert," worked at CFG as insurance brokers, producers,

and agents. Over the years, defendants marketed, sold, and procured insurance

and financial products for plaintiff and his practice, including the four policies

at issue in this case.

Specifically, plaintiff alleged that from 2003 to 2021, he met with Audet

"at least [fifty-one] times" and provided him and Laver with "comprehensive

information" regarding plaintiff's individual and business needs. In particular,

plaintiff discussed his "need for insurance coverage" to cover "LGZ business

expenses" and "to replace his income in the event he suffered a disability that

prevented him from performing neurosurgery." In response, Audet represented

that plaintiff would receive "maximum benefits for the maximum policy

periods[] and premium payments would be waived" under the policies

"regardless of any other factors." Plaintiff alleged that although Audet was

aware of plaintiff's "medical-legal consulting business, which dated back to

2011," at "no time did Audet explain to [plaintiff] that MetLife would consider

A-4093-23 4 income or expenses from any business interest unrelated to LGZ in reviewing a

claim for benefits."

In addition, prior to procuring the IDI policies, Audet allegedly reviewed

plaintiff's "existing disability policy, which was an 'own occupation' policy that

provided coverage if [plaintiff] became injured and was unable to perform

neurosurgery but would allow him to earn income in other vocations while still

receiving disability benefits." After reviewing the policy, Audet advised

plaintiff that the 2003 MetLife IDI policy "'compared favorably' to [plaintiff's]

existing own occupation disability policy."

Plaintiff subsequently developed bilateral maculopathy, a progressive

condition affecting the retina. As a result, plaintiff was unable to perform

surgery and did not operate after September 14, 2021. He was also forced to

"divest his ownership interests in and involvement with LGZ." On November

6, 2021, plaintiff had a teleconference with Laver. This was the "first time" he

"dealt directly with Laver." During the conversation, Laver allegedly informed

plaintiff that "Audet's statements about the coverage provided under the IDI

[p]olicies were false," and that plaintiff "would probably only be covered under

the residual disability benefit provision of the IDI [p]olicies."

A-4093-23 5 In December of 2021, plaintiff filed claims with MetLife under all four

policies. MetLife denied the claims under the BOE policies and only paid partial

benefits under the IDI policies, "claiming benefits are only payable . . . pursuant

to the residual disability provision." Although "MetLife has acknowledged that

[plaintiff] is permanently unable to perform neurosurgery," it claims plaintiff's

"medical-legal consulting business prevents him from being considered totally

disabled under the terms of the IDI . . . and BOE [p]olicies" because "its

definition of [plaintiff's] 'regular occupation' includes revenues and expenses

from his medical-legal consulting business."

Plaintiff alleged that "[t]he first time anyone raised [his] medical-legal

consulting business . . . and related income or expenses as a potential bar to

receiving maximum benefits" under the policies was during his conversation

with Laver "after he suffered his disability and made claims for benefits from

MetLife." Plaintiff continued to talk with Audet and Laver about "advocat[ing]

on his behalf to support his claims for benefits." However, after MetLife denied

his claims for "maximum benefits," Audet and Laver became "less responsive"

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