Hovannisian

I. BACKGROUND

21 Defendant removed this action from state court on May 14, 2019. (ECF No. 1). The 22 underlying complaint asserts breach-of-contract and breach-of-the-implied-covenant-of-good- 23 faith-and-fair-dealing claims against Defendant relating to the denial of an insurance claim for a 24 property located in Hanford, California. (ECF No. 1-5). Generally, Plaintiffs allege that, after the 25 property was destroyed by a fire, Defendant did not investigate their insurance claim in good faith 26 and improperly denied it. 27 A key issue in the litigation is whether Plaintiffs had installed working smoke detectors at 28 the property, which was a condition precedent to coverage and the basis for denial of the insurance claim. (See ECF No. 27, p. 1 (“[O]ne of the critical issues in this coverage matter is whether Plaintiffs complied with the Protective Safeguards Endorsement (which required Plaintiffs to maintain working smoke detectors at the Loss Property) on the Policy at issue.”). The Court held an informal discovery conference on October 12, 2021. (See ECF No. 30). Defendant’s letter brief explained that it had learned from the deposition of “Ivan…