+1
It’s winter, you can’t always count on the roads being clear. I went pretty late before getting some snows with the mild winter, but at least my tires were high performance all seasons, not a pure summer tire. And once it got cold, the snows went on.
But, regardless, stop talking to his insurance company. Call your insurance company and let them fight for you. His agent is playing games hoping you’re dumb enough to slip up and admit fault.