(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) BLUE SHIELD DID NOT COMPLETE ITS MEDICAL UNDERWRITING OR TAKE STEPS TO ANSWER ALL REASONABLE QUESTIONS ARISING FROM THE INFORMATION CONTAINED IN…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) PLAINTIFFS’ OPPOSING SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS DEMONSTRATES THAT DEFENDANTS FACTS ARE DISPUTED AND THAT DEFENDANT’S MOTION MUST THEREFORE BE DENIED.…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) DEFENDANT’S SEPARATE STATEMENT OF UNDISPUTED FACTS AND DEFENDANT’S SUPPORTING EVIDENCE ARE IMPROPER AND OBJECTIONABLE ON NUMEROUS GROUNDS AND SHOULD BE STRICKEN. As…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) THE COURT OF APPEAL’S PUBLISHED DECISION ON PLAINTIFFS’ APPEAL FROM THE FIRST GRANT OF SUMMARY JUDGMENT IN THIS CASE AND ITS DETERMINATION…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) FACTS ESSENTIAL TO JUSTIFY OPPOSITION MAY EXIST BUT CANNOT, FOR REASONS STATED IN THE ACCOMPANYING EXPERT WITNESS DECLARATIONS, NOW BE PRESENTED. DEFENDANT’S…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) 14. Plaintiff Bob Lawrence sustained disabling injuries in an automobile accident on March 19, 2001. 15. On June 5, 2001, Blue Shield…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) STATEMENT OF FACTS 1. Plaintiffs submitted their application for a family health care services contract to Blue Shield in 2000 through insurance…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) Plaintiffs’ complaint against Blue Shield contains causes of action for breach of contract, breach of the implied covenant of good faith and…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment or, in the Alternative, Summary Adjudication of Issues. MEMORANDUM OF POINTS AND AUTHORITIES INTRODUCTION…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident case and its proceedings.) Starting with what plaintiff would have earned if not injured in the automobile collision and subtracting what she is able to earn now…