On January 24, 2020 a Complaint,Petition was filed involving a dispute between Jesse Dunn , and Pacific Specialty Insurance Company , for Unlimited Civil Other Contract in the District Court of Riverside County.
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1 LAW OFFICES OF J. PATRICK RAGAN, APLC J. PATRICIA IIAGAN, ESg, SBN.: I35703 JONATHAN V. KAARIA, ESQ., SBN.: 323134 1881 S. BUSINESS CENTER DRIVE, SUITE 7B SAN BERNARDINO, CALIFORNIA 92408 4 TELEPHONE: (909) 890-4039 5 Attorneys for Plaintiff, JESSE DUNN, an individual. 6 7 SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF RIVERSIDE — HISTORIC COURTHOUSE 9 JESSE DUNN, an individual, CASE NO.: 10 Plaintiff, 11 vs. COMPLAINT FOR DAMAGES FOR: I. BREACH OF CONTRACT PACIFIC SPECIALTY INSURANCE 2. BAD FAITH BREACH OF COMPANY, a California corporation; DOES 1 IMPLIED COVENANT OF GOOD through 50, inclusive, 14 FAITH AND FAIR DEALING Defendants. 3. DECLARATORY RELIEF 15 16 17 18 TO ALL INTERESTED PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: 19 COMES NOW, Plaintiff, JESSE DUNN, an individual (" Plaintiff" ) complains, avers, and 20 alleges as follows: 21 22 PRELIMINARY ALLEGATIONS 23 Plaintiff alleges on information and belief that venue is proper in the County of 24 Riverside (Historic Courthouse) in that the action involves a contract entered into and concerning 25 real property located in the above-captioned Judicial District. 26 Plaintiff alleges on information and belief that Defendant, PACIFIC SPECIALTY 27 INSURANCE COMPANY ("PSIC"), is a California corporation whose principal business 28 purpose is to be an insurer in the State of California, and elsewhere, with its principal business COMPLAINT FOR DAMAGES 1 1 location in Anaheim, California. 3. Plaintiff JESSE DUNN, an individual, at all times herein mentioned, was an 3 insured under a homeowners insurance policy, known as policy number ENG 0749589-01(01), 4 which became effective on May 5, 2020 by P SIC, and which was fully in force and effect (referred 6 to herein as the "Contract" or the "Policy"). A true and correct copy of Plaintiff s policy with 6 P SIC is attached hereto as EXHIBIT 1. In addition, attached hereto as EXHIBIT 2 are true and 7 correct copies of Plaintiff s March 11, 2021 Renewal Notice for the Policy. PSIC agreed to pay 8 the benefits of the policy in accordance with the provisions of the policy. 9 4. At this time, Plaintiff does not know the true names of Defendants DOES 1 10 through 50, inclusive, and therefore sues them by said fictitious names pursuant to California 11 Code of Civil Procedure f 474. Plaintiff is informed and believes, and on that basis alleges, that 12 each of those Defendants was in some manner legally responsible for the events and happenings 13 alleged in this Complaint and for Plaintiff's injuries and damages complained of herein. Plaintiff 14 shall amend this Complaint to insert the true names of each such Defendant, together with the apt and proper words to charge it upon ascertairunent thereof or order of the Court. (DOES 1 through 50 and P SIC shall collectively be referred to hereinafter as "Defendants" ). 17 5. Plaintiff alleges on information and belief that, at all times herein mentioned, each of the Defendants was the agent and employee of each of the remaining Defendants and was at 19 all times herein mentioned acting within the scope of said agency and employtnent. 20 6. At all times herein mentioned, Plaintiff is informed and believes, and thereupon alleges that the Defendants, and each of them, are and were insurance companies, were authorized to conduct and were conducting a liability and casualty insurance business in California and were 23 authorized to issue and administer liability and casualty insurance policies in California. 24 26 COMMON ALLEGATIONS 7. Plaintiff re-alleges and incorporates herein by this reference Paragraphs 1 through 26 27 6, inclusive of the Preliminary Allegations, and makes them a part hereof, as if set forth verbatim 28 herein. COMPLAINT FOR DAMAGES 2 1 8. Plaintiff alleges on information and belief that the above-mentioned Policy 2 provided property damage coverage for the home built in approximately the 1950s and owned 3 by Plaintiff which is located at 876 Ikentwood Drive, Riverside, California 92337 (the "Property" ). 4 9. Plaintiff alleges on information and belief that, on or about March 5, 2021, while 6 the subject insurance Policy was in full force and effect, the above-described Property was 6 damaged by a sudden and inunediate loss of water when Plaintiff turned on his dishwasher 7 resulting in flooding occurring due to the sudden and accidental break of a non-wearing item, a s pipe, that was part of the main drain line located therein. 9.1. Plaintiff alleges on information and belief that, on March 19, 2021, to Plaintiff obtained a written estimate of the cost to repair the covered damages to the Property in 11 the total sum of $ 40,654.95. Attached hereto as EXHIBIT 3 are true and correct copies of i2 estimates to repair the covered damages along with inspection photographs thereof. 13 10. Plaintiff alleges on information and belief that he made a proper and timely claim 14 for the benefits due under the aforementioned insurance Policy as claim number 3180551. Defendants, and each of them, denied the claim and have refused to pay the physical damage 16 benefit. 17 10.1. Plaintiff alleges on information and belief that, shortly afler making his claim, Plaintiff had a verbal discussion with Defendant's Property Claims Adjuster Daneyda i9 Cedeno-Magallanes (the "Adjuster" ) wherein this Adjuster represented to Plaintiff that his claim was approved and that the Adjuster would submit his approved claim to accounting so that payment of $ 12,000.00 could be issued. Shortly thereafter, the Adjuster verbally informed Plaintiff that his claim would need to be submitted to her superior for review prior to payment 23 being issued. 24 11. Plaintiff alleges on information and belief that he complied with all of the conditions precedent to receive the beneiit under the terms and conditions of the Policy from Defendants, Defendants, and each of them, failed to pay Plaintiffs'laim for benefits. 11.1. Plaintiff alleges on information and belief that, after Plaintiff's 27 conversations with the Adjuster, Defendants sent Plaintiff a letter, dated March 26, 2021 denying COMPLAINT EOR DAMAGES 3 his claim in its entirety. A true and correct copy of Defendants'arch 26, 2021 letter is attached 2 hereto as EXHIBIT 4. 3 11.2. Plaintiff alleges on information and belief that Defendant's March 26, 2021 4 letter contended that the Policy did "not provide coverage for damage caused by "repeated leakage 3 and seepage, rot and or mold." See EXHIBIT 4. 11.3. Plaintiff alleges on information and belief that, on June 4, 2021, Plaintiff s 7 attorney sent a letter to Defendants concerning the foregoing March 26, 2021 denial letter. In 3 Plaintiff's June 4, 2021 letter, Plaintiff points out that the portion of the Policy cited in Defendants' March 26, 2021 denial letter, located at Section I, Coverage A, specifically covered Plaintiff for Io "sudden loss except for that caused by 'continuous or repeated seepage or leakage of water [. ] over a period of weeks, months or years from within a plumbing [. ] system'" and, further, given I2 that mold generally appears within only 7 to 10 days and no mold was uncovered on the Property 13 in relation to the pipe at issue, it is "clear that the damages resulting from the leakage of water did 14 not occur over weeks, months or years. Attached hereto as EXHIBIT 5 is a true and correct copy of Plaintiff's June 4, 2021 letter referenced herein. Plaintiff's letter further points out that, even were there some indication of any continuous or repeated leakage, there is no question that the I7 burst pipe resulted in flooding to the Property which occurred suddenly and not over weeks, months or years and that, based on the foregoing, while any damage from continuous seepage California i9 lnay be excluded from coverage pursuant to the quoted portion of the Policy, the damages resulting from the sudden failure of the sink drain line in issue should certainly be covered. 21 11.4. Plaintiff s June 4, 2021 letter also pointed out that the Insurance Code requires that Insurance Companies heat their clients with the utmost "good faith", 23 necessitating the truthful evaluation as to whether a client is entitled to a claim; requirements with 24 which Plaintiff's believe that Defendant failed to comply. Plaintiff then clearly stated that Defendant was to provide his attorney with "any and all documentation to support the basis for [Defendants'] denial of [Plaintiff's] claim by no later than June 21, 2021. Defendants provided 27 no further information despite Plaintiff s demand. /// COMPLAINT FOR DAMAGES 4 IH. 2 FIRST CAUSE OF ACTION 3 (Breach of Contract) 4 12. Plaintiff re-alleges, and incorporates herein by this reference, and makes a part 6 hereof as if verbatim, Paragraphs 1 through 11, inclusive, of the Preliminary Allegations and 6 Common Allegations. 7 13. Plaintiff has duly performed each and every condition of the Policy of insurance s issued by Defendants under which he was obligated to perform. 9 14. Defendants, and each of them, breached their obligations under the contract with 10 the Plaintiff, in that they unreasonably refused to pay the benefit due to Plaintiff under the 11 Contract despite the fact that the sudden and accidental break of the non-wearing item at issue 12 was not caused by wear and tear and resulted in the sudden and immediate loss of water referenced herein which constitutes an event covered by the relevant Policy. 14 15. As a direct and proximate result of Defendants'reach of the contractual duties owed to Plaintiff, Plaintiffhas suffered damages in an amount to be established according to proof at trial but believed to be no less than $ 40,654.95 in benefits due under the insurance policy, plus attorney's fees and cost of suit in an amount to be shown according to proof, in addition to interest as provided by law including, but not limited to, California Civil Code section 3291. See 19 EXHIBIT 3. 20 21 SECOND CAUSE OF ACTION 22 (Bad Faith Breach of Implied Covenant of Good Faith and Fair Dealing) 23 16. Plaintiff re-alleges, and incorporates herein by this reference, and makes a part hereof as if verbatim, Paragraphs 1 through 15, inclusive, of the Preliminary Allegations and First Cause of Action. 26 17. Plaintiff alleges on information and belief that, at all times herein material, Defendants, and each of them, knew, or in the exercise of good faith reasonably should have known, that Plaintiff was legally entitled to recover the benefit under the aforementioned COMPLAINT FOR DAMAGES 6 insurance policy, and that the Defendants, and each of them, were obligated to provide Plaintiff 2 the benefits under the insurance policy. 3 18. Plaintiff alleges on information and belief that Defendants, and each of them, 4 further knew, or in the exercise of good faith reasonably should have known that the policy benefit 6 was due to Plaintiff. Defendants, and each of them, nevertheless, maliciously, intentionally, and 6 oppressively conducted themselves willfully and wrongfully and refused, and failed, to pay the 7 benefits of the policy to Plaintiff, despite the fact that the benefits under the policy were due and 8 payable to the Plaintiff and the Plaintiff was entitled to the full benefits of the policy. 9 19. Plaintiff alleges on information and belief that Defendants, and each of them, Io unreasonably failed to pay Plaintiff's claim for benefits under the policy. All acts of Defendants, 11 and each of them, as herein alleged, were done with the prior approval of, with the knowledge of, 12 and/or under the express direction or ratification of an officer, director, or managing agent of 13 Defendant, PACIFIC SPECIALTY INSURANCE COMPANY, a California corporation, 14 consistent with the definitions contained in California Code of Regulations, Title 10, Section 2695.12. 16 20. Plaintiff alleges on information and belief that, as a proximate result of Defendants'rongful conduct, as aforementioned, Plaintiffhas been denied the receipt ofhis lawful insurance policy benefits despite Defendants'nowledge that the sudden and immediate loss of water 19 caused by the sudden and accidental breakage in the non-wearing item, a drain line, at issue was an event covered thereunder. 21 21. Plaintiff alleges on information and belief that Defendants'ctions in withholding and refusing to pay the policy benefits were unreasonable, malicious, oppressive, fraudulent 23 and/or in bad faith and were intended to willfully injure, harass, vex and annoy Plaintiff with a 24 conscious disregard for Plaintiff's rights. All of the aforementioned alleged acts were done or ratified by Defendants'anagement level employees, who acted with knowledge that Defendant's conduct would cause Plaintiff harm. Plaintiff is therefore entitled to recover punitive 27 damages pursuant to California Civil Code section 3294. 28 22. Plaintiff is informed and believes, and thereon alleges that Defendants'ctions COMPLAINT FOR DAMAGES 6 were part of a practice of Defendants which is designed, among other things, to wrongfully 3 withhold payment of claims with the intent of ignoring the interest of their insured. 3 23. Plaintiff alleges on information and belief that, as a direct and proximate result of 4 Defendants'rongful conduct, as aforesaid, Plaintiff has sustained severe and serious injury including, but not limited to emotional and mental distress, anxiety, frustration, humiliation and 6 indignity all to Plaintiff's damage in a sum within the jurisdiction of this court and to be shown 7 according to proof. 9 THIRD CAUSE OF ACTION 10 (DECLARATORY RELIEF) 11 24. Plaintiff re-alleges, and incorporates herein by this reference, and makes a part 12 hereof as if verbatim, Paragraphs I through 23, inclusive, of the Preliminary Allegations and First 13 Cause of Action. 14 25. Plaintiff alleges on information and belief that an actual controversy has arisen and 15 now exists between Plaintiff and Defendants concerning their respective rights and duties in that Plaintiff claims that Defendants improperly denied his claim in breach of the Policy and in breach of the covenant of good faith and fair dealing while Defendants contend that the denial of IS Plaintiff s claim was appropriate. 19 26. Plaintiff desires a judicial determination of the rights and duties of the respective parties, and a declaration that the denial of Plaintiff's claim was improper pursuant to the terms of the Policy and that the aforesaid denial of Plaintiff's claim by Defendants was in violation of the implied covenant of good faith and fair dealing. 23 27. Plaintiff alleges on information and belief that ajudicial determination is necessary &4 and appropriate at this time under the circumstances in order that Plaintiff may ascertain his rights and duties with respect to his coverage under the Policy and the impropriety of Defendants'enial of his claim as set forth herein. 27 COMPLAINT FOR DAMAGES 7 WHEREFORE, Plaintiff JESSE DUNN, an individual, prays for Judgment against Defendants, 2 and each of them, as follows: On First Cause of Action (Breach of Contract) 1. Benefits due under the insurance policy in a sum to be shown according to proof at trial but believed to be no less than $ 40,645.95; 2. Consequential damages in a sum to be shown according to proof at trial; 3. For attorney fees in an amount to be shown according to proof at trial; 4. For interest provided by law including, but not limited to, California Civil Code section 3291; 10 5. For costs of suit incurred herein; and 6. For such other and further relief as this Court deems just and proper. 12 On Second Cause of Action (Breach of Imnlled Covenant of Good Faith and Fair 13 Dealinu) 14 1. General damages according to proof at trial; 15 2. Benefits due under the insurance policy in a smn to be shown according to proof at 16 trial; 17 3. Consequential damages in a sum to be established shown according to proof at trial; 4. Punitive Damages in an amount to be shown according to proof at trial; 19 5. For attorney fees in an amount to be shown according to proof at trial; 20 6. For interest provided by law including, but not limited to, California Civil Code 21 section 3291; 22 7. For costs of suit incurred herein; and 23 S. For such other and further relief as this Court deems just and proper. 24 On Third Cause of Action (Declaratorv Reliefl 25 1. For a declaratory judgement declaring that the denial of Plaintiff's claim was improper 26 and in breach of the terms of the Policy and of the implied covenant of good faith and 27 fair dealing; 28 2. For a judgment declaring that the damages forming the basis of Plaintiff s claim are COMPLAINT li'OR DAMAGES 8 I to be covered by Defendants by their paytnent of the benefits of the Policy, 2 constituting the estimated costs to repair of $ 40,654.95, to Plaintiff; and 3 3. For such other and further relief as this Court deems just and proper. 4 Dated: January ~7, 2022 LAW OFFICES OF J. PATRICK RAGAN, APLC J. PATRI~RA SQ Attorney for 0 JESSE DUNN dual 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COMPLAINT FOR DAMAGES 9 KXHIEIT 1 ''I. Policy Declarations (Insured Copy) Policy Nou ENG 0749589-00 April 30, 2019 IIIIIIIllIIIEI Pacific Specialty ielusaecs runlmu'i Insurance Provided bv Underwritten Bv MCGRAW INSURANCE SERVICES PACIFIC SPECIALTY INSURANCE COMPA)')Y FINANCIAL RATING: "A" )EXCELLENT) BT BEST P.O. BOX 80 AM /NASEIM, CA 92815-0090 STATUS: ADMITTED Named Insured Insurance Producer JESSE DUNN PRODUCER, 813288, (909)-829-2002 DUNN, SSERI SnaverinsuranceSaoI.Coo 876 KENTWOOD DR SERVER INSURANCE AGENCY RIVERSIDE, CA 92507 17980 ARROW BLVD STE 20 FONI'ANA,CA 92335 www.pacificSoecialty.corn Manage your account. Pay Bills, CA.jLIFO~IA HO-3 Preferred Homeowners For policy servrce/questions contacl (909)-829-2002 or C/8 at 1-800-303-5000 your produoer at IAs Urcince 1 800-982"1172 )For ciarms servrce) This is your Declarations Page INSPKCTIOI)i ADVISORY Thank you for choosing Pacific Specialty Insurance Company for your home insurance, Please review your electronically signed application provided by your producer snd the enclosed declarations pages in their entirety, Please refer to the elected or declined coverages listed and coufirm that you purchased the correct and/or adetluate coverage. If you would like to amend your policy coverages please contact your producer, An independent mspection company will be conducting an exterior and/or interior inspection of your property. For interior inspections, you wiII be contacted by the inspection company to schedule an appointment. This inspection is a iiecessary step in our underwriting process. Pacific Specialty Insurance Company looks forward to providing you with excellent service for all your insurance needs. Sincerely, Pacific Specialty Insurance Company 04/30/2019 0000732-00'l2359 Policy Declarations (insured Copy) Policy No.: ENG 0749589-00 April 30, 2019 g his page was intentionally left blank) 04/30/2019 Policy Declarations (insured Copy) Policy Nod ENG 0749589-00 April 30, 2019 Page I Paci6c Specialty Iw's I muIJJurr sr Insurance Provided bv Underwritten By MCGRAN INSURANCE SERVICES PACIFIC SPECIALTY INSURANCE COMPANY P,O, BOX 40 FINANCIAL RATING: sAs (EXCELLENT) BY AM BESZ ANAHEIM, CA 92815-0040 STATUS: AD)(ITTED Named Insured Insurance Producer JESSE DUNN PRODUCER: 813288, (909)-829"2002 DUNE, SHERI Shaverinsursncegaol.corn 876 KENTNOOD DR SHAVER ZNSIJRANCE AGENL'I'7480 RZVHRSIDE, CA 92507 ARROW BLVD S'IE20 PONTANA, CA 92335 www.PacificSoeciallv.corn Manage your account, Psy hrlls. HO-3 Preferred Homeowners For policy service/questions contact (909)-829-2002 or C/8 at 1-800-303-5000 your producer at Insurance 1 800-962"'I'I72 (For clarms service) This is your Declarations Page Policy No,: ENG 0749589-00 Policy Type: HO-3 PREFERRED PERSONAL HOMEOWNERS Policy Term: May 05, 2019 to May 05, 2020 at 12:01am Standard Time at the address of Named Insured as stated herein Coverage Summary Insured Location: 876 KENTWOQD DR RIVERSIDE CA 92507 Please sse next page for a full list of coverages, credits and ad1ustments applied to your policy, as well as other availahla options. Coveraae Deductible ** DED, UNLESS SPECIAL DED, BEIOW 81,000.00 A DWELLING 8271,000.00 AP PREMZER PACKAGE Al 256 EXTENDED REPLACEMENT COST A2 ORDINANCE OR LAW COVERAGR ).0.004 A3 INFLATION GUARD A6 LIMITED SEWER OR DRAJN BACHUP 810,000.00 8 OTHER STRUCTURES 833,755,00 C PL'RSONAL PROPERTY 8168,771,00 Cl REPIACL" CO 2 PERSONAL PROPL'RTY C4 HOME FREEZER CONTENTS COVERAGE D I,OSS OF USE s54 200 00 PERSONAL LIABILITY 8300,000,0 ~ EBC EQUIPMENT BREAKDOWN COVERAGE EIE AN1MAL LIABILITY EXCLUSION 04/30/2019 0000732-0042361 Policy Declarations (Insured Copy) Policy Nou ENG 0749589-00 April 30, 2019 Page 2 F MEDZCAL PAYMENTS $5,000.00 PPG AGE OP PLUMBING SURCHARGE 5 No. oi years P18 TRtlMPOLZNE UXCLUSZON P19 DIVING BOARD 8 SLIDE EXCLUSION RFR ROOF REPLACEMENT COST SLC SERVICE LINE COVERAGE Policy Coverage Premium (excluding fees): $ 1,176.00 ***THIS IS NDT A BILL*'* Any pnyroeot i ofnrroatt'on will be rettttes ted sepat'ntely (i f applicable). Please read yuar poli cy cnrefitlly for coverage details; Please he aware that an independent inspection company will conduct the required exterior inspection of your property. You do not need to he present for the inspection to occur, 04(30/2019 Policy Declarations (Insured Copy) Policy Nox ENG 0749599-00 April 30, 2019 Page 3 Outline of Coverage Detail C lsre6$ 1,1Hs DS Unl Pnlslum Dwelling A DWELLING $271,000.00 $ 864.DQ Al 251 EXTENDED REPLACEMENT COST INC. B OTHER STRUCTURES $33,'/55,00 $ 17,00 RFR ROOF REPLACEMENT COST Personal Property C PERSONAL PROPERTI'l $168,7'I1.00 $ 33.00 REPLACE COST PERSONII PROPERTY INC, C4 HOME FRESHER CQNTH141S COVERAGE $ 12.00 Liability E PERSONAL LIABILIly $300,000.00 EZE ANIMAL LIABILITT FXCLUSZON INC. F MEDICAL PAYMENTS $5,000.00 $ 9.00 PIS TRAMPOLINE EXCLUSION ZNC. P19 DIVING BOARD & SLIDE L'XCLUSIQN INC, INC . Other AP PREMIER PACKAGE $ 86.00 A2 QRDINAI'1CIU QR LAW COVERAGE 10,006 INC. A3 INFLATION GUARD INC. A6 LIMITED SEWER QR DRAIN BACKUP $10,000.00 $ 75.00 D I,OSS OF USE $54,200.00 EBC EQUIPMENT BREAKDOWN COVERAGE $ 32.00 SLC SERVICE LINE COVERAGE $23.00 Additional Charges PPG AGE OF PLUMBING SURCHARGE 5 No. of years Deductible ** DED, UNLESS SPECIAL DED. BELOW $1,0D0.00 INC. policy novas'aga premium: $ 1, 176. DD pOLIcy FEE (Fully earned) $ 30.00 ZNSPECTION FEL'Fully earnedl $ 40.00 Total 12 Month Pulley Charge $ 1,246,00 Policy and inspection fees, ifcharged, are fully earned (retained). *"* Please be aware that the following fees may apply: -A reinstatement fee of $ 10 will apply if your policy is cancelled and then reinstated. — A cancellation fee of $ 25 will apply if the policy is cancelled at your request. 04/30/2019 0000732 — 0042363 Policy Declarations (Insured Copy) Policy No.: ENG 0749589-00 April 30, 2019 Page 1 ***THIS IS NOT A BILL'** Any poymerd infornf ation will be requested separately (If applicable). P1ease read your poll'Oy carefitlly for coverage tlctails. THIS POLICY DOES NOI INCLUDE OPTIONAL EAATHQUAKE COVERAGE. Lienholder information We send cettain notices such as coverage summanies and cancellat on notaces to the following: Lienholder Lienholder THE HONEY SOURCE INC THE HONEY SOURCE INC ISAOA ISAOA PO BOX 1196 PO BOX 1196 SPRINGPIELD, OH 45501 SPRINGFIL'LD, OH 45501 I,oanNo.: 0031320666 Loan No.: 0031320666 04130/2019 Policy Declarations tinsl)red Copy) Policy Nos ENG 0749689-00 April 30„2019 Page 5 Dvvetlinfj's Estimated Replacement Cost Thank you for choosing to insure your dwelling through pacific specialty Insurance company. Iou and a zepresentative fzom your producer's office recently estimated the replacement. cost of your home using the 360 Value estimating tool in assessing your coverage needs. The estimated replacement cost and ornaof the information you pzovided about your home appears below. Please zeview this along with the enclosed "Understanding the Value of 1'our Some" information sheet. Estimated Cost.to replace your home based on 360value estimating tool: 3234,999,00 Insuxsnce amount you selected on your Homeowners Policy. 0271,000.00 Estimate Number: B27FD9G,02 Estimate Date: 04/30/2019 1'earbuilt: 1963 Total living area: 1, 605 "quare Footage Quality grade. Standard Use: PSIN poof Typel 1004 Composition — 3 Tab Shinqle Garage Type: 2 Car (397 " 576 sq. ft.) httsohed / Bui.lt-ln Pozches: 120 Square Footage Decks: None Fireplace(s): 1 fern Cleazance Fireplace Number of Stories', 1 Story Foundation 'fype. 1004 Concrete Slab Exterior Eall Finish: 1004 Stucco — Traditional Hard Cos.t ldditional hd)'ustment: None The replacement cost calculation containing the valuation used to determine the estimated cost to rebuild your home is available by using ths following UNL. http: //producers.mcgrawgroup.com/webappsy/pps/NG UNN/xx/ENG 0749599-00(02)-rsc.pdf The online version oi the estimate is available for appzoxlsiately 60 days and will show the features of your home that you prov).ded to your pzoducei. lhe dwelling coverage should be an amount suffi.cient to replace the home in the case of a total loss, Please be awaze that it is ultimately the insured's responsibility to obtain adequate insuzanoe coverage. If you feel that the dwelling replacement cost estimated above is insufficient, you should incr'ease the coverage to the amount you feel ie appropriate, 04/30/2019 0000732-0042365 Policy Declarations (Insured Copy) Policy Nod ENG 0749599-00 April 30, 2019 Page 6 Tbe following statement is required by California Insurance code 10103: "The limit of liability for this structure (Coverage A) is based on an estimate of the coat to rahu ld your home, including an approximate cost for the labor materials in your area, and specific infozmation that you have provided about your details home." We encourage you to review youz complete estimate online to confi.zm estimate , 1'ourproducer can assist you with any estimate changes, such as adding more detailed i.nformation about features of your home. The more detail you can add, the more the estimate will reflect the actual features of your home, and the less the estimating tool will need to xelv on assumptions about your home. If you have any questions regards.ngthe 360 value estimate or the coverage amounts you selected ox if you would like an additional copy of the complete 360 Value estimate that was created for your home based on the informatin you provided, please contact youz pzoc)ucez SHAVER MAXIWE 1 at (909)929-2002, Thank you for choosing I'acificSpecialty Insurance Company, ESTWIATED REPLACEMENT COST Understanding the Value of Your Home How to determine vour homeowner's coveraC/e Here is some impoztant info mation to consider when determining the coverage amount fax your home, Wake euce your home ls insured for at least 1009 of i.tsestimated replacement cost We recommend that you purchase an amount.of cov rage at least equal to the estimated replacement cast, The amount of coverage you choose is up to you. It is impossible to predict exactly what the cost of replacing your home be wi,).1 at a future date., so it is important to ensure that you have enough coverage to account for unforeseen circumstances. Determining your home'a estimated zeplacement cost will ultimately determine which pol cy options aze available to you. Understand tha difference between market value and replacement cost Market value is the amount a buyer will pay to purchase a home, including the land, regardless of how much it would cost to rebuild the home. Replacement cost is the cost of repairing or replacing the entire home. Replacement cost is NOT the maxket value of the nome, the puxcliase price or cost of the land, oz the outstanding amount of any mortgage loan. When buying a new home, be sure to obtain a xeplacement cost estimate purchase a new home, make sure that you determine the appropriate amount of insurance coverage you need. When you Ask if a replacement cost estimate is available when you have the home appraised Consult with your local builder association or a reputable builder for an estimate you can also check with your producer to help you with this process Bs aware af any architectural datai.lsor unique building nmterials that may affect your estimated replacement cost, such as: Upgraded bathrooms or kitchens (includ).ngcabinets) Finished or partially finished basemeni Additional rooms or living space Custom molding or arched window. other unique featux'ea 04/30/2019 Policy Declarations (Insured Copy) Policy No.: ENG 0749589-00 April 30, 2019 Page 7 Review your policy annually to make sure that your coverage meets your needs H „ . 11 d 1 d or imuroved~tte? Impi'ovament".s may increase your home's estimated zeplacement coat, Your producer can help you adjust your policy to meet youz coverage needs. pslc provides coverage that automatically adlusts each year in arleffort to compensate for I.ncreases i.n construction costs in your area, Hovrever certain cond?.tions sun?ias se ere weather can increase the demand for labor and mater'als and raise costs beyond normal inflati.on,It is important. to update your coverage amount each year to keep up with the chang ng econoriy. iiarket Conditions in your area may impact the amount it will cost to rebuild your home if you eiiperience a loss. Replacement cost estimate are influenced by supply of labor', demand f'r labor, and the cost of construction materials. Keeping up with the currant market conditions in your azea and updating your coverage amount accordingly, will help you maintain coverage at least equal to 100 percent of the estimated replacement cost coverage for your home. If you have any questions, please cotitact.your producer, hll coverages are sublect to t1ieterms, pzovision, exclusions, and conditions in the policy itself and any applicable endorsements. 04/30/2019 0000722-0062267 Policy Declarations (Insured Copy) Policy No.: ENG 0749589-00 April 30, 2019 Page 0
January 27, 2022
Case Filing DateJanuary 24, 2020
Unlimited Civil Other Contract