Luis Sanchez v. National General Insurance Company

I. BACKGROUND

On September 1, 2021, Mr. Sanchez commenced this action against Defendants National General Insurance Company (“National General”) and Integon National Insurance Company (“Integon”) in the Superior Court of California for the County of San Bernardino. (“Complaint,” Dkt. No. 1, Ex. 1 at 21–23.) On October 20, 2021, Mr. Sanchez filed a first amended complaint against National General, Integon, Freeway Insurance (“Freeway Insurance”), and Does 1 through 120 (collectively, “Defendants”). (“FAC,” Dkt. No. 1, Ex. 1 at 8–20.) The FAC asserts four causes of action arising from car insurance policies Defendants issued to Mr. Sanchez: (1) breach of the implied covenant of good faith and fair dealing (bad faith); (2) unfair business practice in violation of California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code § 17200, et seq.; (3) breach of contract; and (4) negligence. (See FAC.) On December 2, 2021, National General and Integon filed a notice of removal. (“Notice of Removal,” Dkt. No. 1.) Mr. Sanchez filed the Motion on December 29, 2021. (See Mot.) On December 31, 2021, National General and Integon filed a notice of non-opposition. (“Non-…