35.Venue in this Court is proper under 28 U.S.C. § 1391 as a substantial part of the events giving rise to this claim occurred within the Northern District of Alabama.
6.On January 31, 2001, Mr. McGhee, as primary insured, applied toPrimerica for $300,000 in life insurance coverage on his own life. His wife at thattime, Fillis McGhee was designated as the primary beneficiary. No contingent beneficiaries were named. Primerica issued policy number 0432648774 (the“Policy”), with coverage as applied for. A true and correct copy of the Policy isattached hereto as Exhibit A. Later, on or about April 30, 2002, Mr. McGheeapplied for an additional $132,000 in coverage in the form of a term rider to thePolicy. Additionally, a spousal rider insuring Fillis McGhee in the amount of $326,000 was applied for and the Policy was amended pursuant to the April 30,2002 application.7.Mr. McGhee and Fillis McGhee were divorced on December 28,2012, at which time a final decree of divorce
a vinculo matrimonii
was entered bythe Circuit Court for Madison County, Alabama. On January 4, 2013, Mr.McGhee was murdered in front of his home, having been shot multiple timesthrough the back windshield of his car.
Case 5:13-cv-00567-IPJ Document 1 Filed 03/26/13 Page 3 of 8