Jangozian

BACKGROUND

On December 17, 2010, plaintiffs Vartan and Anna Oleva Jangozian sued Farmers Insurance Group and respondent Farmers Insurance Exchange (Farmers) on several theories after Farmers partially denied plaintiffs’ claim for smoke and ash damage to plaintiffs’ house in Glendale resulting from the Station Fire. The operative second amended complaint asserted the following causes of action against Farmers: breach of contract; breach of implied covenant of good faith and fair dealing; violation of Business and Professions Code section 17200; intentional infliction of emotional distress; fraud; and violation of the Unruh Civil Rights Act, Civil Code section 51 (Unruh Act). In allegations incorporated in every cause of action, plaintiffs allege in the second amended complaint that the Station Fire “broke out” on August 26, 2009, and “raged uncontained for more than a month.” Plaintiffs further alleged that the fire “blanketed foothill communities in a thick cloud of ash and left many homes inundated with smoke and ash.” They averred that their own house “was inundated with smoke and ash from 2 that fire, which caused damage to both the exterior and interior of Plaintiffs’…