andrew safir et al vs. bankers standard insurance company complaint

8/4/2019 ANDREW SAFIR ET AL vs. BANKERS STANDARD INSURANCE COMPANY Complaint

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KELLEY DRYE & WARREN LLPMichael J. O'Connor (STATE BAR NO. 90017)

FILEDSUPERIOR COURT OF CALIFORNIA10100 Santa Monica Boulevard, Twenty-Third Floor , .) COUNTY OFLOSANGELESLos Angeles, California 90067-4008Telephone: (310) 712-6100Facsimile: (310) [email protected]

Attorneys for Plaintiffs Andrew Safir andMaralee Beck Safir

. . i ^ A * . - .1 Jo hn A GfcSke, Executive Offioer/CltrBY \dj]f~BhaunyaWei

S U P E R I O R C O U R T OF THE S T A T E OF C A L I F O R N I AC OUNTY OF LOS A N G E L E S , C E N T R A L D I S T R IC T

ANDREW SAFIR and MARALEE BECKSAFIR, as individuals,Plaintiffs,

v.BANKERS STANDARD INSURANCECOMPANY, a Pennsylvania corporation,

Defendant.

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/ / /275142-l.doc

CASENO. B C 4 6 8 3 3 4C O M P L A I N T FOR:1. BREACH OF C O N T R A C T

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2. BAD FAITH TOR TIOUS BR EAC H OFT H E I M P L I E D C O V E N A N T OF G O O DFAITH AND FAIR DEALING3 . D E C L A R A T O R Y R E L I E FJUR Y DEMAND

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COMPLAINT

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Plaintiffs Andrew Safir and Maralee Beck Safir, for their complaint against DefendantBankers Standard Insurance Company ("Bankers"), allege as follows:

NATURE OF THE CASE1. This action arises from Bankers' failure and refusal to honor its obligations to

Plaintiffs, the insureds under "ACE Platinum Portfolio Home Policy" number 268-02-35-35H (the"Po licy"). In September 2 010, Plaintiffs purchased an AC E policy prov iding, inter alia, hom einsurance coverage for the Plaintiffs' property at 450 West Tiehack Road, Aspen, Colorado 81611(the "Property"). On May 16, 2011, the Property and its contents were dama ged. Despite itsobligations to its insureds, Ban kers unjustifiably and in bad faith refused to hono r Plaintiffs' claimfor coverag e under the Policy for the dam age to the Property and its conten ts. By this lawsuit,Plaintiffs seek the insurance cov erage to which they are en titled un der the Policy, as well asdamages for Bankers' bad faith denial of insurance coverage.

THE PARTIES2. Plaintiffs are individuals residing in the State of California.3 . Defendant Bankers is an insurance company organized and existing under the laws

of the state of Pennsylvania with its principal place of business located in Philadelphia,Pennsylvania. Upon information and belief, Bankers is engaged in, among other things, thebusiness of selling policies of insurance through various agents in the County of Los Angeles, andhas an authorized agent for service of process in the County of Los Angeles.

GENERAL ALLEGATIONS4. Plaintiffs purchased the Policy as of Septem ber 27, 2010.5. On or around May 16, 2011, the Property and its contents were damaged by

flowing debris which broke through the windows and doors on the South side of the Property,causing ensuing dam age to the structure and to the personal property w ithin (the "Incid ent"). Thedebris flow filled the Property with mud and water, and covered the personal property within theProperty with several feet of mud and water.

6. Plaintiffs subm itted a claim for water and mud dam age to Bankers on May 17,2011, which was received by a claims adjuster for ACE Private Risk Services (a Bankers'275142.1.doc COMPLAINT


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affiliate) ("ACE") and assigned claim number 77000665 (the "Claim "). ACE advised Plaintiffsthat they must take im mediate steps to prevent further damage to the Property, such as, amongother things:

a. "Have a competent vendor or contractor perform water or moistureextraction"; and

b. "Have air mov ers, dehumidifiers, or fans put into use if recomm ended byyour vendor or co ntractor".

7. ACE advised Plaintiffs to proceed w ith em ergency or temporary repairs, ifrequired, and to keep a record of all such mitigation expenses.

8. Am ong other things, Plaintiffs hired movers to attempt to salvage the personalproperty at the Property and hired contractors to remove the m ud and w ater inside the home andoutside the home to relieve pressure on the structure and prevent further dam age to the home.

9. On June 9, 2011, ACE advised Plaintiffs by letter that it was denying the Claim inits entirety.

10. Plaintiffs have complied with all applicable terms and conditions under the Policy.Further, Plaintiffs timely and properly notified Bankers of the damage that the Property sustained.Additionally, Plaintiffs timely and properly took the recommended immediate steps to preventfurther d amag e to the Property. Plaintiffs requested that Bankers provide insurance coveragepursuant to the terms of the Policy.

11. Bankers has breached its duties to Plaintiffs by failing to provide insurancecoverage on the Claim, and failing to reimburse Plaintiffs for expenses incurred to remediate thedamage and prevent further damage im mediately following the Incident. Bankers has hadrepeated opportunities to investigate the Claim, and the dam age to the Property and its contents,but has refused to pay anything on the Claim.

12. By this action, Plaintiffs seek damages for Bankers' breach of a written insurancecontract, bad faith tortious breach of the implied covenant of good faith and fair dealing, and adeclaration of Ba nkers ' obligations under the Policy.

COMPLAINT


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FIRST C AUSE OF A C T I O N(Breach of Contract)

13 . Plaintiffs incorporate by reference the allegations contained in Paragraphs 1through 12, as though set forth fully herein.

14. Plaintiffs are informed and believe and thereon allege that Bankers issued thePolicy for good and valuable consideration, naming Plaintiffs as the insured s. The Policy has beenin full force and effect at all relevant times, insuring Plaintiffs for the damage caused to theProperty and its contents on May 16,2011.

15. Plaintiffs timely submitted the Claim to Bankers on the grounds that the damage tothe Property and its contents is covered under the term s of the P olicy.16. Plaintiffs have performed all covenants and conditions required of it under thePolicy.

17. Bankers has breached its contractual duties to Plaintiffs under the Policy by failingto provide coverage for the damage to the Property and its contents, and failing to reimbursePlaintiffs for their expenses in remediating the damage to the Property.

18. As a direct and proximate result of Ban kers' breach of contract, Plaintiffs havebeen damaged in a sum w hich is currently unascertainable. Plaintiffs will seek leave of Court toamend this Com plaint when such sum can be reasonably ascertained.

SECOND CAUSE OF ACTION(Breach of the Implied Covenant of Good Faith and Fair Dealing)

19. Plaintiffs incorporate by reference the allegations contained in Paragraphs 1through 18, as though set forth fully herein.

20. Implied into every contract of insurance is a covenant of good faith and fair dealingwhich obligated the insurer, Bankers in this instance, to act at all times in good faith towards itsinsured. Plaintiffs reas onably exp ected that Bankers would protect it against the sort of dam age tothe Property and its contents that occurred on and around M ay 16, 2011, and that Bankers woulddeal with Plaintiffs fairly, equitably and in good faith. This expe ctation w as brought about andintended by Bankers as a result of the contractual language in the Policy.

_ _ _ _ _ _ ^ _ 3COMPLAINT


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21. Bankers has breached the implied covenant of good faith and fair dealing, mostnotably by failing to provide Plaintiffs with cov erage on the Claim for da mag e to the Property andits contents, and failing to reimburse Plaintiffs for their expenses in remediating the dam age to theProperty.

22. The acts and omissions of Bankers as set forth herein were committed in bad faith,intentionally and/or with consciou s and reckless disregard for Plaintiffs' rights. Plaintiffs areinformed and believe , and on that basis allege, that Bank ers intentionally and willfully refused toackno wledge its obligations to provide coverage to Plaintiffs on the C laim. Plaintiffs are furtherinformed and believe, and on that basis allege, the Bankers' sole motivation in denying the Claimand/or stonewalling any good faith consideration of coverage was to save money that should havebeen paid to Plaintiffs under the Policy, for which Bankers w as paid substantial premium s toguarantee such coverage when, and if, needed.

23 . As a direct and proximate result of Bank ers' breach of the implied covenant ofgood faith and fair dealing contained in the Policy, Plaintiffs have suffered general andconsequential damages in an amount in excess of the jurisdictional m inimum of this Court.Plaintiffs w ill seek leave of Court to amend this Com plaint to state the actual, amou nt of da ma geswhen known.

24. Bankers' conduct described above was intended by Bankers to cause injury toPlaintiffs and constituted desp icable condu ct carried on by Bank ers in willful and consciousdisregard of Plaintiffs' rights such as to constitute malice, oppression or fraud as defined byCalifornia C ivil Cod e 32 94. Plaintiffs are therefore en titled to pun itive and exemplary dam agesagainst Bank ers in an amoun t sufficient to punish B ankers and deter it and others from engag ingin similar, unlawful conduct in the future.

T H I R D C A U S E O F A C T I O N(Declaratory Relief)

25. Plaintiffs incorporate by reference the allegations con tained in Paragraphs 1through 24, as thoug h set forth fully herein.

26. An actual controversy has arisen and now exists between Plaintiffs, on the one4COMPLAINT


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hand, and B ankers, on the other hand, relating to their respective legal rights and obligations undethe Policy.

27 . Plaintiffs contend that, pursuant to the terms of the Policy, Bankers has a duty toprovide coverage on the Claim.

28. Plaintiffs are informed and believe, and on that basis allege, that Bankers disputesthe above-alleged contentions.

29. Plaintiffs seek a declaration of the rights and obligations of the parties under thePolicy and specifically seek an adjudication that Bankers is obligated to provide coverage underthe Policy with respect to the Claim.

WHEREFORE, Plaintiffs pray for judgment as follows:ON THE FIR ST C AUSE OF AC TION

1. For the Court to enter judgm ent against Bank ers in a sum in excess of thejurisdictional limit, to be determined according to proof at trial, together with interest thereon atthe maximum statutory rate, fees and costs incurred herein, and such other and further relief as theCourt may deem just and proper.

O N T H E S E C O N D C A U S E O F A C T I O N2. For an award against Ban kers of all actual, general, consequential, and incidental

losses in an am ount to be determined according to proof, together with interest thereon at themaximum statutory rate.

3. For an award of punitive and exemplary damages against Bankers in an amountsufficient to punish Bankers and deter it and others from engaging in similar, unlawful conduct inthe future.

4. For reasonable attorneys' fees.O N T H E T H I R D C A U S E O F A C T I O N

5. For a declaration of rights and obligations of both P laintiffs and Ban kers under thePolicy.

COMPLAINT


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ON ALL CAUSES OF AC TION6. For all costs of suit incurred herein7. For any and all further relief which the Court deems proper.

DEMAND FOR TRIAL BY JURYPlaintiffs hereby demand trial by jury on all issues triable by jury.

DATED: August 24,2011 KELLEY DRYE & WARREN LLPMichael J. O'Connor

Michael JAttorneys for PlaintiflMaralee Beck Safir

COMPLAINT


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tale barnTTORNEY OR PARTY WITHOUT ATTORNEY (Name, StateBar number, and address):"Michael J. O'ConnorKELLEY DRYE S,WARREN LLP10100 Santa Monica Boulevard23rd FloorLos Angeles, CA, 90067-4008

TELEPHONE^.: ( 3 1 0 ) 7 1 2 - 6 1 0 0 FAX NO.: ( 3 1 0 ) 7 1 2 - 6 1 9 9ATTORNEY FOR (Name): A n d r ew S a f i r a n d M a r a l e e B e c k S a f i rSUPERIOR COURT OF CALIFORNIA, COUNTY OF L O S A n g e l e sSTREET ADDRESS: 1 1 1 N o r t h H i l l S t .

MAILING ADDRESS: 1 1 1 N o r t h H i l l S t .CITY AND Z IP CODE: L o s A n g e l e s , 9 0 0 1 2BRANCH NAME: S t a n l e y Mo sk C o u r t h o u s e

CASE NAME: SAFIR V. BANKERS STANDARD IN S. CO.

CM-010FO R COURT USE ONLYFILED

SUPERIOR COURT OF C A I I F D B N I ACOUNTY OF LOS ANGELES^

A U G 2 4 2 0 1 1i0haAffff- Execu"ve 0ff5cef/Clerk

BTT4 6 8 3 MIVIL CASE COVER SHEETm Unlimited Limited(Amount (Amountdemanded demanded isexceeds $25,0QQ) $25,000 or less)Complex Case Designation

I ] Counter I I JoinderFiled with first appearance by defenda nt(Cai. Rules ofCourt, rule 3.402)

CASE

JUDGE:DEPT:

Items 1-6 below must be completed (see instructions1 . Check oneboxbe low for the case type tha t bes t desc r ibes th is case :

Auto TortI I Auto (22)I | Uninsured motorist (46)Other PI/PD/WD (Personal In jury/PropertyDamage/Wrongful Death) Tort

I Asbestos (04)I | Product liability (24)

J Medical malpractice (45)I I Other PI/PD/WD (23)Non-PI/PD/WD (Other) TortI I Business tort/unfair business practice (07)| | Civil rights (08)

3 Defamation (13)I I Fraud (16)I Intellectual property (19)

3 Professional negligence (25)| | Other non-PI/PD/WD tort (35)EmploymentI J Wrongful termination (36)| | Other employment (15)

Contract] ] Breach ofcontract/warranty (06)H Rule 3.740 collections (09)H Other collections (09)

X | Insurance coverage (18)I ] Other contract (37)

Real PropertyI I Eminent domain/Inversecondemnation (14)I H ] Wrongful eviction (33)

Other real property (26)Unlawful Detainer

U Commercial (31)H Residential (32)

I I Drugs (38)Judicial ReviewI Asset forfeiture (05)I ] Petition re: arbitration award (11)| | Writ of mandate (02)I ~2 Other judicial review (39)

on page 2).Provis ional ly Complex Civ i l L i t igat ion(Cal . Rules of Court , ru les 3.400-3.403)

J Antitrust/Trade regulation (03)J Construction defect (10)

| | Mass tort (40)I Securities litigation (28)I Environmental/Toxic tort (30)

I ] Insurance coverage claims arising from theabove listed provisionally complex casetypes (41)

Enfo rcemen t of Judgmen tI | Enforcement of judgment (20)Misce l laneous Civ i l Compla in tI | RICO (27)I | Other complaint (not specified above) (42)Miscel laneous Civ i l Pet i t ion] Partnership and corporate governance (21)I ] Other petition (not specified above) (43)

2. This case I I is I X I isnot com plex under rule 3.400 of the California Rules of Court. If the case is com plex, mark thefactors requiring exceptional judicial management:a. [ ID Large number of separately represented parties d. I I Large number of witnessesb. I I Extensive motion practice raising difficult or novel e. i I Coordination with related actions pending in one or more courts

issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal courtc. [ 3 Substantial amount ofdocumentary evidence f. [ ^ Substantial postjudgment judicial supe rvision

3. Remedies sought (check all that app ly): a. I X I monetary b. I X I nonmone tary; declaratory or injunctive relief c. I X I punitive4. Number of causes of action (specify): T h r e e (3)5. This case I I is [ X I isnot a class action suit.6. If there are any known related cases, file and serve a notice of related c ase . (You may use formjC.Date: A u g u s t 24, 2011M i c h a e l J . O ' C o n n o r

(TYPE OR PRINT NAME)N O T I C EPlaintiff must file this cover sheet with the first paper filed in the action or proceeding (except smalt claims cases or cases filedunder the Probate Code, Fam ily Cod e, or We lfare and Institutions Co de). (Cal. Rules of Court, rule 3.220.) Failure to fi le may resultin sanctions.File this cover sheet in addition to any cover sheet required by local court rule.If this case is complex under rule 3.400 et seq. of the California Rules of Court, you m ust serve a copy of this cover sheet on allother parties to the action orproceeding.Unless this is a collections case under rule 3.740 or a complex ca se, this cover shee t will be used for statistical purposes only._ _ _ ^ _ ^ _ _ _ _ Page 1 ol 2

Form Adopted for Mandatory UseJudicial Council of CaliforniaCM-010 [Rev. July 1.2007]C IV IL C A SE C O VE R SH E E T ?alSolulfq _C^Hus

Cal. Rules ofCourt, rules 2.30, 3,220. 3.40O-3.403, 3.740:Cal. Standards of Judicial Administration, sld. 3.10


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SHORT TITLE: SAFIR v. BANKERS STANDARD INS. CO. CASE NUMBER

CIVIL CASE COVER SHEET ADDENDUM ANDSTATEMENT OF LOCATION(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)s his form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.o em I. Check the types of hearing and fill in the estimated length of hearing expected for this case:J URY T R I A L ? E j Y E S CLAS S ACT ION? LZ1 Y E S L I M I T E D C A S E ? Q Y E S T I M E E S T I M A T E D F O R T R I A L 2 H O U R S / E D A Y SItem II. Indica te the correct district and courthouse location (4 s te p s - If you checked "Limited C ase", skip to Item III, Pg. 4):

S tep 1 : After first completing the C ivil Case Cover S heet form, find the main Civil Case C over Sheet heading for yourcase in the left margin below, and, to the right in Column A , the Civil Case Cover Sheet case type you selected.S tep 2 : Check one Superior Court type of action in Column B below w hich best describes the nature of this case.Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you havechecked. For any exception to the court location, see Local Rule 2.0.

Applicable Reasons for Choosing Courthouse Location (see Column C below)1. Cla ss act io n s mu st b e f il ed in th e S tan le y Mo sk Co u r th o u s e, cen t ra l d ist ri c t .2 . M a y b e Tied i n cen t ra l (o th er co u n ty , o r n o b o d i ly in ju ry /p ro p er ty damage)3 . L o c a t i o n w h e r e c a u s e o f a c t i o n a r o s e .4 . L o c a t i o n w h e r e b o d i ly in j ur y , d e a t h o r d a m a g e o c c u r r e d .5 . L o c a t i o n w h e r e p e r f o r m a n c e r e q u i r e d o r defendant r e s i d e s .

6 . L o c a t i o n o f p r o p e r t y o r p e r m a n e n t l y g a r a g e d v e h i c l e .7 . L o c a t i o n w h e r e p e t i t io n e r r e s i d e s .8 . L o c a t i o n w h e r e i n d e f e n d a n t / r e s p o n d e n t f u n c t i on s w h o l ly .9 . L o c a t i o n w h e r e o n e o r m o r e o f t h e p a r t i e s r e s i d e .1 0 . L o c a t i o n o f L a b o r C o m m i s s i o n e r O f f i c e

Step 4: Fill in the information requested on page 4 in Item III; comp lete Item IV. Sign the declaration .

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ACivil Case Cover SheetCategory No.Auto (22)

Uninsured Motorist (46)

Asbestos (04)

Product Liability (24)

Medical Malpractice (45)

OtherPersonal InjuryProperty DamageWrongful Death(23)

BType of Action(Check only one)D A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death A7110 Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist A6070 Asbestos Property Damage A7221 Asbestos - Personal Injury/Wrongful DeathD A7260 Product Liability (not asbestos or toxic/environmental)D A7210 Medical Malpractice - Physicians & SurgeonsD A7240 Other Professional Health Care Malpractice A7250 Premises Liability (e.g., slip and fall) A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.,

assault, vandalism, etc.) A7270 Intentional Infliction of Emotional DistressD A7220 Other Personal Injury/Property Damage/W rongful Death

cApplicable Reasons -See Step 3 Above1..2..4.1..2..4.

2.2.1. , 2 . ,3 . ,4 . ,8 .t . , 4 .1..4.

1..4.1 ., 4.1 ., 3.1..4.

LACIV-109 ( R e v . 0 3 / 1 1 )L A S C A p p r o v e d 0 3 - 0 4

CIVIL CASE COVER SHEET ADDEN DUMAND STATEMENT OF LOCATION Local Rule 2.0Page 1 of 4


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SHORT TITLE: SAFIR v. BANKERS STANDARD INS. CO . CASE NUMBER

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ACiv i l Case Cover Sheet

Category No.Business Tort (07)

Civi l Rights (08)

Defamat ion (13)

Fraud (16)

Profess ional Negl igence (25)

Other (35)

Wrongfu l Terminat ion (36)

Other Employment (15)

Breach of Cont rac t / Warranty(06)(not insurance)

Collect ions (09)

Insurance Coverage (18)

Other Cont rac t (37)

Eminent Domain/ InverseCondemnat ion (14)

Wrongful Evict ion (33)

Other Real Property (26)

Unlawfu l Deta iner-Commerc ia l(31 )

Unlawfu l Deta iner-Res ident ia l(32)Unlawfu l Deta iner-Pos t -Forec losure (34)

Unlawfu l Deta iner-Drugs (38)

BType of Ac t ion

(Check only one ) A6029 Other Comm erc ia l /Bus iness Tor t (not f raud/breach of cont rac t )

D A60 05 Civ i l Rights /Disc r im inat ion

A601 0 Defamat ion (s lander /l ibe l)

D A6013 Fraud (no contract) A6017 Legal Malpract iceD A60 50 Other Profess ional Malprac t ice (not medica l or legal )

A602 5 Other Non-Personal In jury /Proper ty Dam age tor t

D A6037 Wrong fu l Terminat ion

D A6024 Other Employme nt Comp la in t Case A6109 Labor Commiss ioner AppealsD A6004 Breach of Renta l /Lease Cont rac t (not un lawfu l deta iner or wrongfu levict ion)D A6008 Contract/Warranty Breach -Seller Plaint i f f (no f raud/negligence) A6019 Negl igent Breach of Contract/Warranty (no f raud)D A60 28 Other Breach of ContractM/arranty (not f raud or neg l igence) A60 02 Collect ions Case -Seller Plaint i f f A601 2 Other Promissory Note/Col lec t ions Case0 A601 5 Insurance Covera ge (not complex) A600 9 Cont rac tua l FraudD A60 31 Tor t ious In terferenceD A602 7 Other Cont rac t Dispute(not breach/ insurance/ f raud/negl igence)

A73 00 Eminent Doma in/Condem nat ion Num ber o f parce ls

D A60 23 Wrongfu l Ev ic t ion CaseD A601S Mortgage Forec losureD A6032 Quiet Ti t leD A6060 Other Real Proper ty (not eminent dom ain, landlord/ tenant , forec losure)

D A6021 Unlawfu l Deta iner-Comm erc ia l (not drugs or wrong fu l ev ic t ion)

D A602 0 Unlawfu l Deta iner-Res ident ia l (not drugs or wrongfu l ev ic t ion)

D A6020F Unlawfu l Deta iner-Pos t -Forec losure

A6022 Unlawfu l Deta iner-Drugs

cAppl icab le Reasons -See Step 3 Above1..3.

1..2..3.

1 ., 2 3 .

1 2 3 .1 .. 2. , 3.1 ., 2. , 3.

i2. ,3 .

1 . 2., 3.

1 ., 2., 3.1 0.

2 5 .2 5 .1..2., 5.1.,2 5.

2. , 5.. 6.2 5.1.(2/0,8.1 ., 2., 3., 5.1.2., 3., 5.1.,2., 3.. 8.

2 .

2 ., 6.2 6 .2. , 6.2. , 6.

2. , 6.

2 6 .

2. , 6.

2. , 6.

LACIV 109 (Rev. 03/11)LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION Local Rule 2. 0Page 2 of 4


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Item III. Statement of Location: Enter theaddress of the accident, party's residence or place of business, performance, or othercircumstance indicated in Item II., S te p 3 on Page 1 , as the proper reason for filing in the court location you selected.

REASON: Check the appropriate boxes for the numbers shownunder Column C for the type of action that you have selected forthis case. 1. 0 2 . D 3. D 4 . 0 5 . 06 . D7 . D8 . 0 9 . 0 1 0 .

CITY:LOS ANGELES

STATE:CA

ZIP CODE:90048

ADDRESS:C/O RECON RESEARCH6380 WILSHIRE BOULEVARD#1604

Item IV. Declaration ofAssignment: I declare under penalty of perjury under the laws of the State of California that the foregoing is truand correct and that the above-entitled matter is properly filed for assignment to the Stanley Mosk courthouse in the

CentralRule 2.0. subds. (b), (c) and (d)].

District of the Superior Court of California, County of Los Angeles [Code Civ. P roa, 392 et seq., and Local

Dated: August 24, 2011(SIGNATURE OF ATTORNEY/I

PLEASE HAVE THE FOLLOWING ITEMS COM PLETED AND READY TO BE FILED IN ORDER TO PROPERLYCOMMENCE YOUR NEW COURT CASE:1. Original Complaint or Petition.2. If filing a Complaint, a completed Summons form for issuance by the Clerk.3. Civil Case Cover Sheet, Judicial Council form CM-010.4. Civil Case Cover Sheet Addendum and Statement of Location form , LACIV 109, LASC Approved 03-04 (Rev.03/11).5. Payment in full of the filing fee, unless fees have been waived.6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-01 0, if the plaintiff or pe titioner is aminor under 18 years of age will be required by C ourt in order to issue a summons.7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendummust be served along with the summons and complaint, or other initiating pleading in the case.

LACIV 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2. 0

andrew safir et al vs. bankers standard insurance company complaint

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