Schmidt

I. Background

22 Plaintiffs commenced this action on December 17, 2021 (Doc. 1) and filed their operative 23 first amended complaint on September 28, 2022. (Doc. 39-1). Plaintiffs raise a claim for breach 24 of contractual duty to pay a covered claim and a claim for breach of the implied covenant of good 25 faith and fair dealing. Id. at 1. Plaintiffs are beneficiaries to life insurance policies that 26 Defendants allegedly breached by failing to pay the death benefits provided in the policies. (Doc. 27 63-1 p. 1). Plaintiff Schmidt is the sole beneficiary of a life insurance policy issued by Standard (and assumed by Protective) to her late-husband, Arthur James Schmidt. (Doc. 39-1 p. 1). Plaintiff Vann-Eubanks is a 50 percent beneficiary of a life insurance policy issued by Protective to her late-father, Robert L. Eubanks. Id. at 3. Plaintiff Vann-Eubanks seeks to represent a class of individuals whose life insurance policies were improperly lapsed due to Defendants’ alleged non-compliance with California Insurance Code §§ 10113.71 and 10113.72, which impose grace- period and notice requirements for life insurance policies. (Doc. 63-1 p. 2).1…