Many opinions have addressed the fact that a court in Texas has no discretion to ignore an appraisal clause that allows either the insurer or the policyholder to invoke it.  The next wave of cases will likely address whether the timely payment of an umpire award moots all other causes of action brought by the policyholder.  Bad faith litigation has matured to the point where it is "good law" that without a breach of contract, there can be no cause of action for bad faith.  It is also "good law" that prompt payment of an umpire award estops the policyholder from bringing a breach of contract cause of action.  So, where does that leave matters?  If an insurer timely pays the full amount of an umpire award and moves for summary judgment on estoppel by contract argument, is there any justification, other than to run up fees and expenses, for the case to continue?  Is there any discovery that is relevant to the estoppel argument that should be allowed?  Although I believe the courts have already answered these questions, I anticipate that the answers to these questions will be reaffirmed in the