KELLEY DRYE & WARREN LLP Michael J. O'Connor (STATE BAR NO.

90017) 10100 Santa Monica Boulevard, Twenty-Third Floor Los Angeles, California 90067-4008 Telephone: (310) 712-6100 Facsimile: (310) 712-6199 moconnor@kelleydrye.com Attorneys for Plaintiffs Andrew Safir and Maralee Beck Safir

FILED
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SUPERIOR COURT OF CALIFORNIA

COUNTY OFLOSANGELES
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SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 1 ANDREW SAFIR and MARALEE BECK 1 SAFIR, as individuals, 12 Plaintiffs, 13 v. BANKERS STANDARD INSURANCE 15 COMPANY, a Pennsylvania corporation, 14 16 17 18 19 20 21 22 23 24 25 26 27 28
/// /// /.// /// /// /// /// /// /// w /// 275142-l.doc
cat at

CASENO.

BC468334

COMPLAINT FOR: 1. BREACH OF CONTRACT 2. BAD FAITH TORTIOUS BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING 3. DECLARATORY RELIEF JURY DEMAND

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COMPLAINT

Plaintiffs Andrew Safir and Maralee Beck Safir, for their complaint against Defendant

2 Bankers Standard Insurance Company ("Bankers"), allege as follows: 3 4 1. NATURE OF THE CASE This action arises from Bankers' failure and refusal to honor its obligations to

5 Plaintiffs, the insureds under "ACE Platinum Portfolio Home Policy" number 268-02-35-35H (the 6 "Policy"). In September 2010, Plaintiffs purchased an ACE policy providing, inter alia, home 7 insurance coverage for the Plaintiffs' property at 450 West Tiehack Road, Aspen, Colorado 81611 8 (the "Property"). On May 16, 2011, the Property and its contents were damaged. Despite its 9 obligations to its insureds, Bankers unjustifiably and in bad faith refused to honor Plaintiffs' claim
10 for coverage under the Policy for the damage to the Property and its contents. By this lawsuit,

11 Plaintiffs seek the insurance coverage to which they are entitled under the Policy, as well as
12 damages for Bankers' bad faith denial of insurance coverage.

13
14 15

THE PARTIES 2. 3. Plaintiffs are individuals residing in the State of California. Defendant Bankers is an insurance company organized and existing under the laws

16 of the state of Pennsylvania with its principal place of business located in Philadelphia,

17 Pennsylvania. Upon information and belief, Bankers is engaged in, among other things, the 18 business of selling policies of insurance through various agents in the County of Los Angeles, and 19 has an authorized agent for service of process in the County of Los Angeles. 20 21 22 4. 5. GENERAL ALLEGATIONS Plaintiffs purchased the Policy as of September 27, 2010. On or around May 16, 2011, the Property and its contents were damaged by

23 flowing debris which broke through the windows and doors on the South side of the Property, 24 causing ensuing damage to the structure and to the personal property within (the "Incident"). The 25 debris flow filled the Property with mud and water, and covered the personal property within the 26 Property with several feet of mud and water. 27 6. Plaintiffs submitted a claim for water and mud damage to Bankers on May 17,

28 2011, which was received by a claims adjuster for ACE Private Risk Services (a Bankers'
275142.1.doc

COMPLAINT

1 affiliate) ("ACE") and assigned claim number 77000665 (the "Claim"). ACE advised Plaintiffs 2 that they must take immediate steps to prevent further damage to the Property, such as, among 3 other things: 4 a. "Have a competent vendor or contractor perform water or moisture

5 extraction"; and 6 b. "Have air movers, dehumidifiers, or fans put into use if recommended by

7 your vendor or contractor". 8 7. ACE advised Plaintiffs to proceed with emergency or temporary repairs, if

9 required, and to keep a record of all such mitigation expenses. 10 8. Among other things, Plaintiffs hired movers to attempt to salvage the personal

1 property at the Property and hired contractors to remove the mud and water inside the home and 1 12 outside the home to relieve pressure on the structure and prevent further damage to the home. 13 9. On June 9, 2011, ACE advised Plaintiffs by letter that it was denying the Claim in

14 its entirety. 15 10. Plaintiffs have complied with all applicable terms and conditions under the Policy.

16 Further, Plaintiffs timely and properly notified Bankers of the damage that the Property sustained. 17 Additionally, Plaintiffs timely and properly took the recommended immediate steps to prevent 18 further damage to the Property. Plaintiffs requested that Bankers provide insurance coverage 19 pursuant to the terms of the Policy. 20 11. Bankers has breached its duties to Plaintiffs by failing to provide insurance

21 coverage on the Claim, and failing to reimburse Plaintiffs for expenses incurred to remediate the 22 damage and prevent further damage immediately following the Incident. Bankers has had 23 repeated opportunities to investigate the Claim, and the damage to the Property and its contents, 24 but has refused to pay anything on the Claim. 25 12. By this action, Plaintiffs seek damages for Bankers' breach of a written insurance

26 contract, bad faith tortious breach of the implied covenant of good faith and fair dealing, and a 27 declaration of Bankers' obligations under the Policy. 28

COMPLAINT

1 2 3 13.

FIRST CAUSE OF ACTION (Breach of Contract) Plaintiffs incorporate by reference the allegations contained in Paragraphs 1

4 through 12, as though set forth fully herein. 5 14. Plaintiffs are informed and believe and thereon allege that Bankers issued the

6 Policy for good and valuable consideration, naming Plaintiffs as the insureds. The Policy has been 7 in full force and effect at all relevant times, insuring Plaintiffs for the damage caused to the 8 Property and its contents on May 16,2011. 9 15. Plaintiffs timely submitted the Claim to Bankers on the grounds that the damage to

10 the Property and its contents is covered under the terms of the Policy. 11 12 Policy. 13 17. Bankers has breached its contractual duties to Plaintiffs under the Policy by failing 16. Plaintiffs have performed all covenants and conditions required of it under the

14 to provide coverage for the damage to the Property and its contents, and failing to reimburse 15 Plaintiffs for their expenses in remediating the damage to the Property. 16 18. As a direct and proximate result of Bankers' breach of contract, Plaintiffs have

17 been damaged in a sum which is currently unascertainable. Plaintiffs will seek leave of Court to 18 amend this Complaint when such sum can be reasonably ascertained. 19 20 21 19. SECOND CAUSE OF ACTION (Breach of the Implied Covenant of Good Faith and Fair Dealing) Plaintiffs incorporate by reference the allegations contained in Paragraphs 1

22 through 18, as though set forth fully herein. 23 20. Implied into every contract of insurance is a covenant of good faith and fair dealing

24 which obligated the insurer, Bankers in this instance, to act at all times in good faith towards its 25 insured. Plaintiffs reasonably expected that Bankers would protect it against the sort of damage to 26 the Property and its contents that occurred on and around May 16, 2011, and that Bankers would 27 deal with Plaintiffs fairly, equitably and in good faith. This expectation was brought about and 28 intended by Bankers as a result of the contractual language in the Policy. ______^_ 3
COMPLAINT

21.

Bankers has breached the implied covenant of good faith and fair dealing, most

2 notably by failing to provide Plaintiffs with coverage on the Claim for damage to the Property and 3 its contents, and failing to reimburse Plaintiffs for their expenses in remediating the damage to the 4 Property. 5 22. The acts and omissions of Bankers as set forth herein were committed in bad faith,

6 intentionally and/or with conscious and reckless disregard for Plaintiffs' rights. Plaintiffs are 7 informed and believe, and on that basis allege, that Bankers intentionally and willfully refused to 8 acknowledge its obligations to provide coverage to Plaintiffs on the Claim. Plaintiffs are further 9 informed and believe, and on that basis allege, the Bankers' sole motivation in denying the Claim 10 and/or stonewalling any good faith consideration of coverage was to save money that should have 11 been paid to Plaintiffs under the Policy, for which Bankers was paid substantial premiums to 12 guarantee such coverage when, and if, needed. 13 23. As a direct and proximate result of Bankers' breach of the implied covenant of

14 good faith and fair dealing contained in the Policy, Plaintiffs have suffered general and 15 consequential damages in an amount in excess of the jurisdictional minimum of this Court. 16 Plaintiffs will seek leave of Court to amend this Complaint to state the actual, amount of damages 17 when known. 18 24. Bankers' conduct described above was intended by Bankers to cause injury to

19 Plaintiffs and constituted despicable conduct carried on by Bankers in willful and conscious 20 disregard of Plaintiffs' rights such as to constitute malice, oppression or fraud as defined by 21 California Civil Code 3294. Plaintiffs are therefore entitled to punitive and exemplary damages 22 against Bankers in an amount sufficient to punish Bankers and deter it and others from engaging 23 in similar, unlawful conduct in the future. 24 25 26 25. THIRD CAUSE OF ACTION (Declaratory Relief) Plaintiffs incorporate by reference the allegations contained in Paragraphs 1

27 through 24, as though set forth fully herein. 28 26. An actual controversy has arisen and now exists between Plaintiffs, on the one
4
COMPLAINT

1 hand, and Bankers, on the other hand, relating to their respective legal rights and obligations under 2 the Policy. 3 27. Plaintiffs contend that, pursuant to the terms of the Policy, Bankers has a duty to

4 provide coverage on the Claim. 5 28. Plaintiffs are informed and believe, and on that basis allege, that Bankers disputes

6 the above-alleged contentions. 7 29. Plaintiffs seek a declaration of the rights and obligations of the parties under the

8 Policy and specifically seek an adjudication that Bankers is obligated to provide coverage under 9 the Policy with respect to the Claim. 10 11 12
13

WHEREFORE, Plaintiffs pray for judgment as follows: ON THE FIRST CAUSE OF ACTION 1. For the Court to enter judgment against Bankers in a sum in excess of the

14 jurisdictional limit, to be determined according to proof at trial, together with interest thereon at
15

the maximum statutory rate, fees and costs incurred herein, and such other and further relief as the

16 Court may deem just and proper. 17

18

ON THE SECOND CAUSE OF ACTION 2. For an award against Bankers of all actual, general, consequential, and incidental

19 losses in an amount to be determined according to proof, together with interest thereon at the 20 maximum statutory rate.
21 22 23 24 25

3.

For an award of punitive and exemplary damages against Bankers in an amount

sufficient to punish Bankers and deter it and others from engaging in similar, unlawful conduct in the future. 4. For reasonable attorneys' fees. ON THE THIRD CAUSE OF ACTION 5. For a declaration of rights and obligations of both Plaintiffs and Bankers under the

26 27 Policy. 28

COMPLAINT

1 2 3 4 5

ON ALL CAUSES OF ACTION 6. 7. For all costs of suit incurred herein For any and all further relief which the Court deems proper. DEMAND FOR TRIAL BY JURY Plaintiffs hereby demand trial by jury on all issues triable by jury. KELLEY DRYE & WARREN LLP Michael J. O'Connor

6 DATED: August 24,2011 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Michael J Attorneys for Plaintifl Maralee Beck Safir

COMPLAINT

CM-010
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, StateBar number, and address): tale barn FOR COURT USE ONLY

"Michael J. O'Connor KELLEY DRYE S, WARREN LLP 10100 Santa Monica Boulevard 23rd Floor Los Angeles, CA, 90067-4008
TELEPHONE^.: (310) 712-6100
Safir

SUPERIOR COURT OF C A I I F D B N I A COUNTY OF LOS A N G E L E S ^

FILED

F X NO.: A

(310)

712-6199
Safir
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ATTORNEY FOR (Name): A n d r e w

and Maralee

Beck

AUG 2 4 2011
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SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS A n g e l e s STREET ADDRESS: 1 1 1 N o r t h H i l l S t . M I I G ADDRESS: 1 1 1 N o r t h H i l l S t . ALN

CITY AND ZIP CODE: L o s A n g e l e s , BRANCH NAME: S t a n l e y M o s k 90012 Courthouse

"

5cef/Clerk

CASE NAME:
m

SAFIR V. BANKERS STANDARD I N S . CO.

Complex Case Designation I ] Counter I I Joinder Filed with first appearance by defendant (Cai. Rules of Court, rule 3.402)
(see
CASE

CIVIL CASE COVER SHEET Unlimited Limited

(Amount (Amount demanded demanded is exceeds $25,0QQ) $25,000 or less)

BTT4 6 8 3 M

JUDGE: DEPT:

Items 1-6 below must be completed

instructions on page 2). Provisionally Complex Civil Litigation (Cal. Rules of Court, rules 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 the above listed provisionally complex case types (41)

1. Check one box below for the case type that best describes this case: Auto Tort Contract I I Auto (22) I | Uninsured motorist (46) Other PI/PD/WD (Personal Injury/Property Damage/Wrongful Death) Tort I Asbestos (04) I I I | 3 I I 3 | | Product liability (24) J Medical malpractice (45) I Other PI/PD/WD (23) I Business tort/unfair business practice (07) | Civil rights (08) Defamation (13) I Fraud (16) Intellectual property (19) Professional negligence (25) | Other non-PI/PD/WD tort (35) I | I I Non-PI/PD/WD (Other) Tort ] ] Breach of contract/warranty (06) H Rule 3.740 collections (09) H Other collections (09) X | Insurance coverage (18) I ] Other contract (37) Real Property I I Eminent domain/Inverse condemnation (14) Other real property (26) Unlawful Detainer U Commercial (31) H Residential (32) I Drugs (38) I Asset forfeiture (05) ] Petition re: arbitration award (11) | Writ of mandate (02) ~2 Other judicial review (39) Judicial Review

I H ] Wrongful eviction (33)

Enforcement of Judgment I | Enforcement of judgment (20) Miscellaneous Civil Complaint I I | RICO (27) | Other complaint (not specified above) (42) ] Partnership and corporate governance (21) I ] Other petition (not specified above) (43)

Miscellaneous Civil Petition

Employment I J Wrongful termination (36) | | Other employment (15)

2. This case I I is I X I is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management: a. [ ID Large number of separately represented parties d. I I Large number of witnesses b. 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 court c. [ 3 Substantial amount of documentary evidence f. [ ^ Substantial postjudgment judicial supervision 3. Remedies sought (check all that apply): a. I X I monetary b. I X I nonmonetary; declaratory or injunctive relief c. I X I punitive 4. Number of causes of action (specify): T h r e e ( 3 ) 5. This case I I is [ X I is not a class action suit.

6. If there are any known related cases, file and serve a notice of related case. (You may use formjC. Date: A u g u s t 2 4 , 2 0 1 1 M i c h a e l J . O'Connor
(TYPE OR PRINT NAME)

NOTICE Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except smalt claims cases or cases filed under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result in 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 must serve a copy of this cover sheet on all other parties to the action or proceeding. Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.
_ _ _ ^ _ ^ _ _ _ _ Form Adopted for Mandatory Use Judicial Council of California CM-010 [Rev. July 1.2007] Page 1 ol 2

CIVIL CASE COVER SHEET

?al Solulfq _ C^Hus

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

SHORT TITLE:

CASE NUMBER

SAFIR v. BANKERS STANDARD INS. CO.

s
o

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.

'em I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? E j YES C L A S S A C T I O N ? LZ1 YES LIMITEDCASE? Q Y E S TIME ESTIMATED FOR TRIAL 2 HOURS/ E DAYS

Item II. Indicate the correct district and courthouse location (4 steps- If you checked "Limited Case", skip to Item III, Pg. 4): Step 1 : After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected. Step 2: Check one Superior Court type of action in Column B below which 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 have checked. For any exception to the court location, see Local Rule 2.0. Applicable Reasons for Choosing Courthouse Location (see Column C below)
1. 2. 3. 4. 5. Class actions must b e filed in the Stanley M o s k Courthouse, central district. M a y be Tied in central (other county, or no bodily injury/property d a m a g e ) Location w h e r e cause of action a r o s e . Location w h e r e bodily injury, death or d a m a g e occurred. Location w h e r e performance required or defendant resides. 6. 7. 8. 9. 10. Location Location Location Location Location of property or permanently g a r a g e d vehicle. w h e r e petitioner resides. wherein defendant/respondent functions wholly. w h e r e o n e or m o r e of the parties reside. of Labor C o m m i s s i o n e r Office

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

A
Civil Case Cover Sheet Category No.

B
Type 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 Death A7260 Product Liability (not asbestos or toxic/environmental) A7210 Medical Malpractice - Physicians & Surgeons 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.) D A7270 Intentional Infliction of Emotional Distress A7220 Other Personal Injury/Property Damage/Wrongful Death

c
Applicable Reasons See Step 3 Above 1..2..4. 1..2..4. 2. 2. 1., 2.,3.,4.,8. t.,4. 1..4.

2
3 O

Auto (22) Uninsured Motorist (46)

Asbestos (04) n. >o r a. ra c> v -1

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Product Liability (24)

D D

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Medical Malpractice (45)

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Other Personal Injury Property Damage Wrongful Death (23)

1..4. 1., 4. 1., 3. 1..4.

L A C I V - 1 0 9 (Rev. 0 3 / 1 1 ) L A S C Approved 0 3 - 0 4

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 1 of 4

SHORT TITLE:

CASE NUMBER

SAFIR v. BANKERS STANDARD INS. CO.

A
Civil Case Cover Sheet Category No. Business Tort (07)
S"i

B
Type of Action (Check only one) D D A6029 Other Commercial/Business Tort (not fraud/breach of contract) A6005 Civil Rights/Discrimination A6010 Defamation (slander/libel) A6013 Fraud (no contract) A6017 Legal Malpractice A6050 Other Professional Malpractice (not medical or legal) A6025 Other Non-Personal Injury/Property Damage tort A6037 Wrongful Termination A6024 Other Employment Complaint Case A6109 Labor Commissioner Appeals A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful eviction) A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence) A6019 Negligent Breach of Contract/Warranty (no fraud) A6028 Other Breach of ContractM/arranty (not fraud or negligence) A6002 Collections Case-Seller Plaintiff A6012 Other Promissory Note/Collections Case A6015 Insurance Coverage (not complex) A6009 Contractual Fraud A6031 Tortious Interference A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)

c
Applicable Reasons See Step 3 Above 1..3. 1..2..3. 1., 2 3 . 1 2 3. 1.. 2., 3. 1., 2., 3.
i

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Civil Rights (08) Defamation (13) Fraud (16)

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1/1
1

5
Professional Negligence (25)

rn a . ra c E o ca z a

01

D Other (35) Wrongful Termination (36) D D Other Employment (15) D Breach of Contract/ Warranty (06) (not insurance) D D

2.,3. 1 . 2., 3. 1., 2., 3. 10.

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25. 25. 1..2., 5. 1.,2 5.

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Collections (09) Insurance Coverage (18) 0 Other Contract (37) D D Eminent Domain/Inverse Condemnation (14)

2., 5.. 6. 2 5.

1.(2/0,8.
1., 2., 3., 5. 1 . 2 . , 3., 5. 1.,2., 3.. 8.

A7300 Eminent Domain/Condemnation

Number of parcels

2.

01

Wrongful Eviction (33)

D D

A6023 Wrongful Eviction Case A601S Mortgage Foreclosure A6032 Quiet Title A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure)

2., 6. 26. 2., 6. 2., 6.

f0 0)

Other Real Property (26)

D D

Unlawful Detainer-Commercial (31) ai Unlawful Detainer-Residential (32) Unlawful DetainerPost-Foreclosure (34) Unlawful Detainer-Drugs (38)

A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction)

2., 6.

A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction)

26.

a "5 TO

A6020F Unlawful Detainer-Post-Foreclosure

2., 6.

A6022 Unlawful Detainer-Drugs

2., 6.

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

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 2 of 4

SHORT TITLE:

CASE NUMBER

SAFIR v. BANKERS STANDARD INS. CO. A

Civil Case Cover Sheet Category No. Asset Forfeiture (05) Writ of Mandate (02)
T3 3

B
Type of Action (Check only one) A6108 Asset Forfeiture Case A6115 Petition to Compel/Confirm/Vacate Arbitration A6151 Writ - Administrative Mandamus A6152 Writ - Mandamus on Limited Court Case Matter

c
Applicable Reasons See Step 3 Above 2.. 6. 2., 5. 2.. 8. 2. 2. 2., 8. 1.,2.,8. 1.,2 3. 1., 2., 8. 1..2..8. 1..2..3., 8. 1.,2.,5.,8. 2., 9. 2., 6. 2., 9. 2., 8. 2., 8. 2., 8., 9. 1,2,8. 1.,2.,8. 2., 8. 1..-2., 8. 1.,2.,8. 2., 8. 2.. 3., 9. 2.,3.,9. 2.. 3., 9. 2. 2., 7. 2., 3.4., 8. 2,9.

5
QJ QJ

Petition re Arbitration (11)

a.

O A6153 Writ - Other Limited Court Case Review Other Judicial Review (39) Antitrust/Trade Regulation (03) D A6150 Other Writ/Judicial Review A6003 Antitrust/Trade Regulation A6007 Construction Defect A6006 Claims Involving Mass Tort A6035 Securities Litigation Case A6036 Toxic Tort/Environmental

TO

Construction Defect (10) Claims Involving Mass Tort (40) Securities Litigation (28) Toxic Tort Environmental (30) Insurance Coverage Claims from Complex Case (41)

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Q

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w D.

Q A6014 Insurance Coverage/Subrogation (complex case only) D A6141 Sister State Judgment A6160 Abstract of Judgment A6107 Confession of Judgment (non-domestic relations) A6140 Administrative Agency Award (not unpaid taxes) A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax A6112 Other Enforcement of Judgment Case A6033 Racketeering (RICO) Case A6030 Declaratory Relief Only A6040 Injunctive Relief Only (not domestic/harassment) A6011 Other Commercial Complaint Case (non-tort/non-complex) A6000 Other Civil Complaint (non-tort/non-complex) A6113 Partnership and Corporate Governance Case A6121 Civil Harassment A6123 Workplace Harassment

C C 01 <u

Enforcement of Judgment (20) D D RICO (27) D Other Complaints (Not Specified Above) (42) D D D Partnership Corporation Governance (21) D

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n o u Other Petitions (Not Specified Above) (43)

O A6124 Elder/Dependent Adult Abuse Case A6190 Election Contest A6110 Petition for Change of Name A6170 Petition for Relief from Late Claim Law A6100 Other Civil Petition

D_ fl) r^ (J i/l > o

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

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 3 of 4

SHORT TITLE:

CASE NUMBER

SAFIR v. BANKERS STANDARD INS. CO.

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.
ADDRESS:

REASON: Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected for this case.

C/O RECON RESEARCH 6380 WILSHIRE BOULEVARD #1604

1. 0 2 . D3. D4. 0 5 . 0 6 . D7. D8. 0 9 . 010.

CITY: STATE: ZIP CODE:

LOS ANGELES

CA

90048

Item IV. Declaration of Assignment: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that the above-entitled matter is properly filed for assignment to the Stanley Mosk courthouse in the Central District of the Superior Court of California, County of Los Angeles [Code Civ. Proa, 392 et seq., and Local Rule 2.0. subds. (b), (c) and (d)].

Dated: August 24, 2011

(SIGNATURE OF ATTORNEY/I

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE 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-010, if the plaintiff or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case.

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

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

Local Rule 2.0 Page 4 of 4