James Kim v. Mapfre Insurance Company

I. Background

On February 11, 2019, Plaintiff filed this case in Los Angeles Superior Court, asserting claims against Defendant for breach of contract, breach of the implied covenant of good faith and fair dealing, and negligence. See Complaint, Dkt. # 1-4 (“Compl.”). Plaintiff, both in the complaint and in a pre-litigation interview with Defendant, stated that he is “an individual residing in Los Angeles County” with “a home located in Upland, California. /d. 1; Transcript of Video Examination, Dkt. # 9-1, (“Video Tr.”), 17:1-2. The complaint seeks damages of at least $250,000, plus interest, costs, and punitive damages. Compl. 7 15, 22. On February 26, 2019, Defendant was served with the summons and complaint, and it filed an answer on March 26, 2019. See Answer, Dkt. # 1-4. Defendant searched various databases in a nationwide public records search for Plaintiff's domicile, and on May 1, 2019, ascertained that Plaintiff was a citizen of California based on property ownership and marital records. Declaration of Tahereh Mahmoudian, Dkt. # 1-2 (“Mahmoudian Decl.”), § 5 & Ex. 1; Opp. 3:8-10. On May 10, 2019, ten days after Defendant learned of Plaintiff's…