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Find out what one of the other claimants is getting or demanding, so carrier can’t argue that they can’t make a determination because of the policy being depleated. send a bad faith demand within the policy, include a package with bills and amount of lost wages, proposed release, etc.
Main difference is that 1st party operates on more of a statutory remedy regime for failure to settle a claim (vs the threat of excess judgement and extracontractuals). Most jurisdictions have specific notice requirements, so make sure you follow all that stuff and just prepare to file suit within 60 days etc
So basically, instead of countering, file suit?