Kristina Bain Golem v. Standard Insurance Company

I. BACKGROUND

Golem is an individual residing in the State of California. Dkt. 1, Ex. 1 (Compl.) ¶ 1. Standard is an Oregon corporation with its principal place of business in Portland, Oregon. Id. ¶ 2. The City of Los Angeles is located in the County of Los Angeles, California. Id. ¶ 3. Standard issued a group accidental death and dismemberment policy (the Policy) to the City, covering City employees who elected and paid for the coverage. Id. ¶ 5. Employees who were covered by the Policy were provided with a certificate listing the terms and conditions

1 The unopposed requests for judicial notice are granted. of the Policy. Id. ¶ 6. Golem’s late husband, Adam Golem (the Decedent), was covered by the Policy, which provided him with $500,000 in accidental death and dismemberment insurance. Id. ¶¶ 5, 7-8. The Policy issued to the Decedent provided in part that Standard would pay benefits if he or his dependent “have an accident” resulting in a loss while insured under the Policy. Id. ¶ 8. The Policy defined loss as “loss of life, hand, foot, sight, speech, hearing in both ears, thumb and index finger of the same hand, coma, and Uniplegia, Quadriplegia, Hemiplegia, or…