O'Neill

BACKGROUND

22 A. Complaint Allegations 23 In 2015 Plaintiff purchased a health insurance policy (the “Policy”) from Defendants. 24 (Dkt. No. 1-2 at 7.) Shortly after the Policy went into effect, Defendants falsely terminated the 25 Policy for non-payment. (Id. at 7.) Defendants reinstated the Policy a month later, only to

27 Record citations are to material in the Electronic Case File (“ECF”); pinpoint citations are to the terminate it again in December 2015. (Id.) Defendants’ actions deprived Plaintiff of acupuncture benefits for 2015. (Id. at 8.) Defendants also “falsified documents, committing mail, wire, phone, and tax fraud to accept payments from Plaintiff and the State of California while denying the existence of the policy.” (Id.) Defendants engaged in an identical pattern of conduct throughout 2016 and 2017 when Defendants terminated the Policy, reinstated it, and terminated again. (Id. at 8, 9.) Additionally, Defendants refused to pay Plaintiff’s acupuncture expenses incurred from 2016 and 2017. (Id. at 9.) By 2018, Defendants’ conduct had severely harmed Plaintiff’s credit score and left her indebted to medical…