A U.S. District Court for the District of Arizona dismissed a claim for abuse of process in Grabinski v. National Union Fire Ins. Co. of Pittsburgh, Pa., No. V041751PHXMHM, 2005 WL 2412784 (D. Ariz. Sept. 23, 2005).

 Thomas Grabinski was insured by a National Union directors and officers policy, as an officer of the Baptist Foundation of Arizona. With criminal charges pending against him, he sought an advance of defense costs from National Union.

 When National Union did not pay, Grabinski successfully sued the insurer for bad faith and breach of contract. A jury awarded him a $2.5 million judgment. National Union appealed and requested a stay of judgment and posted a supersedeas bond (a bond required of one who petitions to set aside a judgment or execution and from which the other party may be made whole if the action is unsuccessful—Black's Law Dictionary, sixth edition).