1LINET MEGERDOMIAN, ESQ. (SBN.

253898)
1 MEGERDOMIAN LAW OFFICES, P.C.
2 468 N. Camden Drive, Suite 220
Beverly Hills, CA 90210
3 Telephone: (877) 734-3095
Facsimile: (818) 272-8634
4 E-mail: lm@megerdomianlaw.com

5 Attorney for Plaintiff

6
7
8 1 1 SUPERIOR COURT FOR THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SAN BERNARDINO
10
11
ROBERT LICON, an individual, CASE NO: CIVSB2223293
12
Plaintiff,
13 vs.

14 CALIFORNIA AUTOMOBILE PLAINTIFFS’ REQUEST FOR

INSURANCE COMPANY, a corporation, PRODUCTION OF DOCUMENTS, SET ONE
15
and DOES 1-20, Inclusive, TO DEFENDANT CALIFORNIA
16 AUTOMOBILE INSURANCE COMPANY
Defendants.
17 Filing Date: 10/12/2022
18
19
PROPOUNDING PARTY: ROBERT LICON
20
RESPONDING PARTY: CALIFORNIA AUTOMOBILE INSURANCE COMPANY
21
SET NO.: ONE
22
23 Pursuant to Section 2031.010 et seq. of California Code of Civil Procedure, Plaintiff
24 Robert Licon (“Plaintiff”) hereby demand that Defendant California Automobile Insurance
25 Company (“Defendant”) produce the documents specified below for inspection and copying
26 within 30 days of service hereof, at Law Offices of Megerdomian Law Office P.C, 320 N Central
27 Ave Suite 102, Glendale, CA 91203. Defendant may comply with this demand by transmitting

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1
PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
 the documents and physical evidence by mail or overnight delivery service so long as they arrive
1
at the designated place within the time required.
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In accordance with Section 2031.250 of the California Code of Civil Procedure, Defendant
3
also must serve within 30 days after service of this Demand a verified written response,
4
responding separately to each item or category of item included in the demand by a statement
5 that Defendant will comply with the particular demand for inspection, a representation that
6 Defendant lacks the ability to comply with the particular demand, or an objection to the
7 particular demand.
8
9 DEFINITIONS

10
A. "YOU" and "YOUR" includes Defendant California Automobile Insurance Company,
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their agents, employees, accountants, investigators, and anyone else acting on her behalf,
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excluding YOUR attorneys.
13
B. “PLAINTIFF” refers to ROBERT LICON.
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C. “DEFENDANT” refers to CALIFORNIA AUTOMOBILE INSURANCE COMPANY.
15 D. The term "DOCUMENT" means a writing, as defined in Evidence Code Section 250,
16 and includes the original or a copy of handwriting, typewriting, printing, photostating,
17 photographing, and every other means or recording upon any tangible thing and form of
18 communicating or representation, including letters, words, pictures, sounds, or symbols,
19 or combinations of them.

20 E. The term “COMMUNICATIONS” refers to all discussions, conversations, interviews,

negotiations, face-to-face meetings, telephone conversations, correspondence, inter-office
21
or intra-office memoranda, email, or other forms of oral or written intercourse, however
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transmitted, and whether or not transmitted.
23
F. “RELATING TO” and “PERTAINING TO” mean consisting of, referring to,
24
referencing, describing, discussing, constituting, evidencing, containing, reflecting,
25 mentioning, concerning, pertaining to, relating to, citing, summarizing, analyzing or
26 bearing any connection with the matter discussed.
27 G. “ANY” shall also mean “all” and vice-versa.
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PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
 H. POLICY” means Plaintiffs’ policy with Defendant CALIFORNIA AUTOMOBILE
1
INSURANCE COMPANY bearing policy number CAHP0000596909.
2
3 I. “CLAIM” means Plaintiffs’ claim against Defendant CALIFORNIA AUTOMOBILE
INSURANCE COMPANY bearing claim number CAHO 00147447.
4
J. “OUR OPTIONS” refers to Section I. of Plaintiffs’ policy, which reads:
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“If we give you written notice within 30 days after we receive your signed, sworn proof of
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loss, we may repair or replace any part of the damaged property with material or property of like
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kind and quality. At our option, we may take all or any part of the property at the agreed or
8 appraised value.”
9 REQUEST FOR PRODUCTION
10
11 REQUEST FOR PRODUCTION NO. 1:

12 Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has

13 been kept in the regular course of business: CALIFORNIA AUTOMOBILE INSURANCE

COMPANY policy number CAHP0000596909 issued by Defendant to Plaintiff, including all
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attachments, endorsements, amendments, and/or riders from date of first issue to Plaintiff until
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the present.
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REQUEST FOR PRODUCTION NO. 2:
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Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
18 been kept in the regular course of business: Any and ALL DOCUMENTS or
19 COMMUNICATIONS comprising the complete claim files (including, but not limited to, home
20 office, regional office, local or other office) pertaining to the claims, including the following;
21 (a) All inter-office memoranda or other form of DOCUMENTS or COMMUNICATIONS of
22 any employee of defendant relating to the initial processing of the CLAIM listed above when

23 YOU first received said CLAIM;

(b) All inter-office memoranda or other form of DOCUMENTS or COMMUNICATIONS
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from any employee of defendant relating to the continued processing of Plaintiff’ CLAIM listed
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above;
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(c) ALL DOCUMENTS or COMMUNICATIONS between Plaintiff and Defendant,
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including all proof of loss forms and/or personal property lists;
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3
PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
 (d) ALL DOCUMENTS or COMMUNICATIONS between defendant and any third party
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concerning the processing, acceptance, or denial of the claims listed above;
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(e) All investigative reports concerning Plaintiff and the claims listed above, and ALL
3
DOCUMENTS or COMMUNICATIONS between defendant and any third party concerning said
4
report or reports;
5 (f) All inter-office memoranda or other form of DOCUMENTS or COMMUNICATIONS
6 from any employee of defendant concerning denial of the claims listed above;
7 (g) ALL DOCUMENTS or COMMUNICATIONS between Defendant and Plaintiff
8 concerning denial of the claims listed above;
9 (h) ALL DOCUMENTS or COMMUNICATIONS between Defendant and any third party or

10 third party’s attorney concerning denial of the claims listed above;

(i) All photographs, motion pictures, videotapes, tape recordings (or transcripts of tape
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recordings) or investigative reports of Defendant concerning Plaintiff taken by or on behalf of
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Defendant, relating to the processing or denial of the claims listed above;
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(j) All other DOCUMENTS or COMMUNICATIONS including correspondence, telephone
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notes, Telex, and fax pertaining to the processing of the above claims in the possession of
15 Defendant not designated in requests numbered (a) through (i);
16 (k) All file folders or file jackets and adjacent or related exhibit folders in which any
17 DOCUMENTS, COMMUNICATIONS or other materials or items described in requests
18 numbered (a) through (i) above are filed or maintained.
19 REQUEST FOR PRODUCTION NO. 3:

20 Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
been kept in the regular course of business: The complete and original underwriting file
21
(including, but not limited to, home office, regional office, local or other office) pertaining to the
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Policy from the time Plaintiffs’ application was submitted up to and including the present,
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including, but not limited to, the file folder or file folders themselves; adjacent exhibit folders;
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(a) ALL DOCUMENTS, COMMUNICATIONS and investigative reports regarding the
25 Policy, including inter-office memoranda or notes pertaining to the issuance of the Policy;
26 (b) and any and ALL DOCUMENTS, COMMUNICATIONS or statements made between
27 defendant and other parties, regarding the issuance of the POLICY.
28 REQUEST FOR PRODUCTION NO. 4:
4
PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
 Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
1
been kept in the regular course of business: The complete claims manuals and/or procedures
2
manuals, policy statements, DOCUMENTS, bulletins, COMMUNICATIONS or memoranda
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which set forth company practices or policies regarding the handling, processing and/or
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investigation of claims submitted by YOUR insureds and which were in effect or which were
5 utilized by YOU at the time the CLAIM was handled, processed and/or investigated.
6 REQUEST FOR PRODUCTION NO. 5:
7 Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
8 been kept in the regular course of business: All additions, revisions, deletions or other changes
9 that have been made in the CLAIMS manuals and/or procedures manuals from the time the

10 CLAIM was submitted up to and including the present.

REQUEST FOR PRODUCTION NO. 6:
11
Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
12
been kept in the regular course of business: Any other DOCUMENTS or COMMUNICATIONS
13
including, but not limited to, inter-office memoranda, notes, files or reports outlining or
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describing procedures for claims handling, processing and investigation and which were in effect
15 or which were utilized by you at the time the claim was handled, processed and/or investigated.
16 REQUEST FOR PRODUCTION NO. 7:
17 Any and ALL DOCUMENTS or COMMUNICATIONS regarding written standards for the
18 prompt investigation and processing of claims adopted by Company in compliance with 10 Cal
19 C. Regs. § 2695.6(b) which were in effect since January of 2020.

20 REQUEST FOR PRODUCTION NO. 8:

Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
21
been kept in the regular course of business: The complete underwriting manual and/or
22
procedures manuals, policy statements, bulletins, DOCUMENTS, COMMUNICATIONS or
23
memoranda which set forth company practices or policies regarding the handling, processing
24
and/or investigation of applications for insurance submitted to and which were in effect or which
25 were utilized by you at the time Plaintiffs’ applications were submitted, handled, processed
26 and/or investigated.
27 REQUEST FOR PRODUCTION NO. 9:
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5
PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
 Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
1
been kept in the regular course of business: All additions, revisions, deletions or other changes
2
that have been made in the underwriting manual and/or procedures manuals from the time
3
Plaintiffs’ applications were submitted up to and including the present.
4
REQUEST FOR PRODUCTION NO. 10:
5 Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
6 been kept in the regular course of business: Any other DOCUMENTS or COMMUNICATIONS
7 including, but not limited to, inter-office memoranda, notes, files or reports outlining or
8 describing procedures for claims handling, processing and investigation and which were in effect
9 or which were utilized by you at the time the claim was handled, processed and/or investigated.

10 REQUEST FOR PRODUCTION NO. 11:

Any and ALL DOCUMENTS or COMMUNICATIONS regarding written standards for the
11
prompt investigation and processing of claims adopted by YOU in compliance with 10 Cal C.
12
Regs. § 2695.6(b) which were in effect since January of 2020.
13
REQUEST FOR PRODUCTION NO. 12:
14
Pursuant to Evidence Code section 1550, a true and correct copy of the following item which has
15 been kept in the regular course of business: The complete underwriting manual and/or
16 procedures manuals, policy statements, bulletins, DOCUMENTS, COMMUNICATIONS or
17 memoranda which set forth company practices or policies regarding the handling, processing
18 and/or investigation of applications for insurance submitted to and which were in effect or which
19 were utilized by you at the time Plaintiffs’ applications were submitted, handled, processed

20 and/or investigated.
REQUEST FOR PRODUCTION NO. 13:
21
All DOCUMENTS that support Your decision not to accept the offer to settle the underlying
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CLAIM.
23
REQUEST FOR PRODUCTION NO. 14:
24
ALL DOCUMENTS, which relate to any communication between YOU and ANY THIRD
25 PARTY relating to the CLAIM.
26 REQUEST FOR PRODUCTION NO. 15:
27 ALL DOCUMENTS that pertain to when the “OUR OPTIONS” part of the policy was enforced
28 by YOU.
6
PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
 REQUEST FOR PRODUCTION NO. 16:
1
ALL DOCUMENTS which support or relate to the CLAIM, including, but not limited to, ALL
2
claim file(s), correspondence, notes, reports regarding the “OUR OPTIONS” portion of the
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POLICY.
4
REQUEST FOR PRODUCTION NO. 17:
5 Provide a copy of the Servpro of La Puente/City of Industry West report, including estimates,
6 photographs, and any supporting documentation related to restoration costs related to this
7 CLAIM.
8 REQUEST FOR PRODUCTION NO. 18:
9 Provide any documents, memoranda, or communications related to the interpretation of policy

10 language, specifically concerning the terms "repair" and "replace”.

REQUEST FOR PRODUCTION NO. 19:
11
Produce all documents supporting the defendant's position justifying the denial or partial denial
12
of the CLAIM, including any calculations, assessments, or internal communications.
13
REQUEST FOR PRODUCTION NO. 20:
14
Produce documents, including internal guidelines, policies, or communications, that outline the
15 defendant's practices for handling claims in good faith and ensuring fair dealing.
16 REQUEST FOR PRODUCTION NO. 21:
17 Provide details on any internal policies, training, or directives related to claim handling and the
18 avoidance of punitive damages.
19 Date: October 24, 2022
20
21
____________________________
22
Megerdomian Law Offices, P.C.
23
Linet Megerdomian, Esq.
24 Attorney for Plaintiffs
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PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
 PROOF OF SERVICE
1
1013a (3) CCP Revised 01/01/19
2
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3
I am employed in the County of Los Angeles, State of California. I am over the age of 18
4
and not a party to the within action. My business address is 320 N. Central Avenue, Glandale,
5 CA 91203.

6 On August 4, 2023, I served the foregoing document described as PLAINTIFFS’

7 REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE) on the interested parties in
this action, addressed as follows:
8
Mary H. Kim
9 WESIERSKI & ZUREK, LLP
10 29 Orchard Road, Lake Forest, CA 92630
Telephone: 949.975.1000
11 Emails: mkim@wzllp.com
Attorneys for Defendants
12 CALIFORNIA AUTOMOBILE INSURANCE COMPANY
13
By mail, I deposited such envelope(s) in the mail at Los Angeles, California, with
14 postage thereon fully prepaid.
15 By facsimile, I transmitted such documents from Los Angeles, California, to the offices
16 of the addressee(s).

17 By personal service, I delivered such envelope(s) by hand to the office(s) of the

addressee(s).
18
19 By email, I emailed the document to the email address of the addressee(s).

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(State) I declare under penalty of perjury under the laws of the State of
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California that the foregoing is true and correct.
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(Federal) I declare that I am employed in the office of a member of the Bar of
23 this Court, at whose direction the service was made.
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Executed on August 4, 2023 at Los Angeles, California.
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26 __________________________
27 Nicole Sheftolovic

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PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)