171819202122232425262728Plaintiffs Andrew Safir and Maralee Beck Safir, for their complaint against DefendantBankers Standard Insurance Company ("Bankers"), allege as follows:
NATURE OF THE CASE
.This action arises from Bankers' failure and refusal to honor its obligations toPlaintiffs, the insureds under "ACE Platinum Portfolio Home Policy" number 268-02-35-35H (the"Policy"). In September 2010, Plaintiffs purchased an ACE policy providing, inter alia, homeinsurance coverage for the Plaintiffs' property at 450 West Tiehack Road, Aspen, Colorado
(the "Property"). On May 16,
the Property and its contents were damaged. Despite itsobligations to its insureds, Bankers unjustifiably and in bad faith refused to honor Plaintiffs' claimfor coverage under the Policy for the damage to the Property and its contents. By this lawsuit,Plaintiffs seek the insurance coverage to which they are entitled under the Policy, as well asdamages for Bankers' bad faith denial of insurance coverage.
Plaintiffs are individuals residing in the State of California.
Defendant Bankers is an insurance company organized and existing under the lawsof
state of Pennsylvania with its principal place of business located in Philadelphia,Pennsylvania. Upon information and
Bankers is engaged in, among other things, thebusiness of selling policies of insurance through various agents in the County of Los Angeles, andhas an authorized agent for service of process in the County of Los Angeles.
Plaintiffs purchased the Policy as of September
On or around May
the Property and its contents were damaged byflowing debris which broke through the windows and doors on the South side of
Property,causing ensuing damage to the structure and to the personal property within (the "Incident"). Thedebris flow filled the Property with mud and water, and covered the personal property within theProperty with several feet of mud and water.6. Plaintiffs submitted a claim for water and mud damage to Bankers on May
which was received by a claims adjuster for ACE Private Risk Services (a Bankers'