Simonyan

I. BACKGROUND

In the operative complaint, Simonyan alleges that, on October 18, 2017, he came to a stop near an intersection and was rear-ended by a truck. He alleges the impact forced his car to hit the car in front of him. At the time of the accident, Simonyan was insured by Nationwide. He contacted them to make a claim. He alleges that, after taking his statement regarding what happened, Nationwide made an internal decision that he was liable for causing the accident. Simonyan retained Gavrilov & Brooks to represent him with respect to the collision. In December 2017, Simonyan filed suit against the driver of the truck that hit him. In May 2018, Simonyan notified Nationwide that he had been sued by the driver of the car that he had hit. Under the terms of the policy, Nationwide had agreed to “pay damages for ‘bodily injury’ or ‘property damage’ for which any ‘insured’ becomes legally responsible because of an auto accident. . . . We will settle or defend, as we consider appropriate, any claim or suit asking for these damages. In addition to our limit of liability, we will pay all defense costs we incur.” The policy requires Simonyan, as a person seeking coverage, to…