Because the Municipal Risk Retention Pool is an insurer created under state law and member municipalities, the notice of claim statute applies. A.R.S. § 12-821.01 Plaintiff missed both the notice of claim deadline and the statute of limitations deadlines for claims against public entities. The Court of Appeals affirmed summary judgment for the Risk Pool. The second issue was whether a separate bad-faith claim can be asserted against a third-party administrator. No. The Court of Appeals agreed that there is no contractual relationship between a third-party claim administrator and an insured, and that the insured had no direct claim. There was also no “joint venture.” But, the Court of Appeals concluded that the trial court erred in awarding the administrator attorney’s fees under § 12-341.01. This makes sense when there is no contractual relationship. Apparently, plaintiff’s counsel has lost this same issue in federal district court. The defendant argued that the award of fees should be upheld because the case was frivolous. While the district court case may be persuasive, it is not precedent. The Court of Appeals sent the issue of frivolity back to the trial court. One judge tacked on a concurrence and acknowledged that, although no one raised it, the Risk Pool is a public entity and is therefore subject to the Open Meeting and Public Records law. One may ask, “So, what?” Many public entities have risk departments, claim handlers, and attorneys. Is the judge suggesting that this is all an open book?