SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY

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1 THE HONORABLE CAROL MURPHY SUPERIOR COURT OF WASHINGTON FOR THURSTON COUNTY TARVA LEE, ) ) No: Plaintiff, ) ) v. ) COMPLAINT FOR BREACH OF ) CONTRACT, BAD FAITH, FARMERS INSURANCE COMPANY ) NEGLIGENCE AND VIOLATION OF WASHINGTON, a Washington ) OF STATUTORY DUTIES State Corporation, ) ) Defendant. ) ) This First Amended Complaint repeats the allegations set forth in the Plaintiff s Complaint, and now adds claims against FARMERS INSURANCE COMPANY OF WASHINGTON, a Washington State Corporation. COMES NOW the Plaintiff, Tarva Lee, by and through her attorneys of record, Cross Border Law Corporation, and alleges the following: I. PARTIES 1.1 Plaintiff Tarva Lee has at all times relevant to this action been a resident of Las Vegas, Nevada. COMPLAINT WEST ND AVENUE # (0) -

2 Defendant Farmers Insurance Company of Washington ( Farmers ) has at all times relevant to this action been a Washington State corporation, conducting business within the State of Washington. State. COMPLAINT - II. JURISDICTION AND VENUE.1 Jurisdiction over Defendant Farmers lies pursuant to its residence in Washington. Venue for this action lies in Thurston County, as the Breach of Contract, Bad Faith and Violation of statutory duties involve a contract between Steven Yaworski and the Defendant that was entered into in Thurston County. III. FACTUAL BACKGROUND THE COLLISION.1 On November, 0, the Plaintiff was involved in an automobile accident north of Williams Lake, British Columbia, Canada. The Plaintiff was a front seat passenger in a vehicle driven by Washington State resident Steven L. Yaworski, when Mr. Yaworski failed to heed the road and weather conditions and reduce his speed, thereby losing control of his vehicle and causing a single-vehicle accident. The Plaintiff was injured in the accident resulting in a permanent disability.. As a passenger in Mr. Yaworski s vehicle, the Plaintiff had access to increased insurance coverage for Mr. Yaworski s third party tort liability (Part of the British Columbia Insurance (Vehicle) Regulations), increased coverage for her own medical and rehabilitation expenses (Part ) and increased coverage for her own underinsured motorist protection (Part ) ( UMP ) under Mr. Yaworski s policy with Farmers, due to Farmers having signed a certain Power of Attorney and Undertaking ( PAU ) with the Canadian Council of Insurance Regulators ( CCIR ) on September, 0. The monetary limits of the insurance coverage 0 WEST ND AVENUE # (0) -

3 are CAD $0,000 for third party liability, CAD $,000 for medical and rehabilitation expenses and CAD $1,000,000 for UMP.. The Plaintiff relies on British Columbia law in enforcing her rights under the Washington contract. Under the PAU, and pursuant to British Columbia law, Farmers must compensate the Plaintiff according to the same terms that B.C. residents are compensated by the Insurance Corporation of British Columbia ( ICBC ). See Part to the Insurance (Vehicle) Act, R.S.B.C ch. 1 and Insurance (Vehicle) Regulations, B.C. Reg. /, S. 1.1 and 1.; see also Ruckheim v. Robinson, {} 1 B.C.L.R.d,, (B.C. Ct. App.); see also Diotte v. Ins. Corp. of B.C., {00} C.C.L.I.d 1 (B.C. Sup. Ct.); see also Anderson v. Co-Operators Gen. Ins. Co., {0} 1 B.C.L.R.d (B.C. Ct. App.).. The Plaintiff has clearly demonstrated to Farmers that she sustained a catastrophic brain injury that will leave her permanently disabled, as well as a host of other injuries and losses. The Plaintiff therefore demanded payment of the maximum third party, medical and rehabilitation expense and UMP coverage provided to her by way of Steven Yaworski s policy as affected by the PAU, subject to relevant deductions for certain benefits under British Columbia law.. In or about June 0, Farmers paid the Plaintiff the maximum CAD $0,000 in third party tort liability coverage and the maximum CAD $,000 in medical and rehabilitation expenses. Farmers, through its counsel, has admitted that, in addition to the $0,000 it has paid to the Plaintiff, it is liable to the Plaintiff for up to $1 million in Canadian funds, subject only to applicable deductions. Although the burden of proof for such deductions under British Columbia law rests with Farmers, Farmers has neither delineated nor proposed any such deductions. Moreover, Farmers has either refused to pay, neglected to pay, or delayed in COMPLAINT - 0 WEST ND AVENUE # (0) -

4 paying the Plaintiff as required, forcing the Plaintiff to initiate UMP arbitration proceedings in British Columbia pursuant to the British Columbia Insurance (Vehicle) Regulations. Attached as Exhibit 1 to this Complaint is a copy of the Notice of Arbitration filed in British Columbia. IV. RESERVATION OF RIGHTS Further particulars of the Defendant s breach of contract, breach of statutory duties and negligence are likely to become evident through the discovery process, and the Plaintiff reserves the right to amend this complaint and/or to present further allegations consistent with the evidence to the fullest extent permitted under Washington law V. FIRST CAUSE OF ACTION-BREACH OF CONTRACT.1 Each of the above allegations is incorporated herein by this reference.. Under its Policy, Defendant contracted to provide UIM coverage to its first party insureds including passengers in the principal insured s vehicle while that vehicle was travelling on the roads of British Columbia, Canada, in exchange for premium payments paid by Steven Yaworski. Steven Yaworski made all premium payments and the contract of insurance was in full force at the time of the loss.. Defendant has breached the contract of insurance by failing to abide by its terms and pay covered damages.. Defendant's breach of contract has caused damage to the Plaintiff. VI. SECOND CAUSE OF ACTION-BAD FAITH.1 Each of the above allegations is incorporated herein by this reference. COMPLAINT - 0 WEST ND AVENUE # (0) -

5 Defendant has a duty to Plaintiff and the contracting public to conduct itself in good faith respecting its obligations as an insurer.. Defendant's acts and omissions, as alleged herein, are a breach of its duty to deal in good faith with its insured, and have caused damage to Plaintiff.. Defendant's acts and omissions are contrary to its insureds' best interests and Defendant's acts are in bad faith, and indeed outrageous.. The acts and omissions of Defendant are unfair and deceptive. VII. THIRD CAUSE OF ACTION - NEGLIGENCE.1 Each of the above allegations is incorporated herein by this reference.. Defendant owed statutory, contractual and common law duties to Plaintiff, which were breached by Defendant's conduct as alleged herein.. Defendant's discharge of its duties was negligent.. By its acts and omissions, Defendant negligently inflicted physical, emotional, and financial distress on Plaintiff.. Defendant's breach of the duties owed to Plaintiff proximately caused damage to the Plaintiff. VIII. FOURTH CAUSE OF ACTION-VIOLATION OF WASHINGTON CONSUMER PROTECTION ACT (RCW.).1 Each of the above allegations is incorporated herein by this reference.. The business of insurance, as well as the practice of insurers, agents, and adjustors, is subject to the Consumer Protection Act ( CPA ), RCW., et seq. COMPLAINT - 0 WEST ND AVENUE # (0) -

6 . The acts and omissions of Defendant and its employees, as alleged herein, during the course of their insurance business, are subject to the CPA, RCW., et seq.. Defendant's actions are unfair, deceptive and violate the CPA, RCW. et seq.. Defendant by and through its employees violated the CPA, RCW. et seq., thereby causing damage to Plaintiff and entitling Plaintiff to treble damages, attorneys fees, costs, and such other relief permitted by the Court.. The acts and omissions of Defendant Farmers violate WAC et seq., including WAC -0-0, WAC -0-0 and WAC -0-0, constituting per se violations of the Consumer Protection Act, codified as RCW. et seq IX. FIFTH CAUSE OF ACTION-VIOLATION OF THE INSURANCE FAIR CONDUCT ACT (RCW.0).1 Each of the above allegations is incorporated herein by this reference.. By its actions it is clear that Defendant holds its monetary interests as more important than its insured s interests. Defendant's acts and practices are contrary to the fair claims practice regulations codified in the Washington Administrative Code, including but not limited to Sections -0-0, -0-0 and Defendant's acts and omissions, as alleged herein, constitute unreasonable conduct and violate RCW.0 et seq., entitling Plaintiff to treble damages, attorneys fees, costs of suit, and such other relief permitted by the Court. COMPLAINT - 0 WEST ND AVENUE # (0) -

7 On November,, Plaintiff provided Farmers at least days notice of this lawsuit as required by RCW.0.01()(a). Farmers has failed to cure the cause for the day letter. X. RELIEF SOUGHT.1 As a proximate result of Defendant's acts and omissions, Plaintiff suffered past, present and future special and general damages, including, but not limited to, the negligent infliction of emotional distress, in amounts to be proven at the time of trial.. Wherefore Plaintiff prays for past, present and future special and general damages in amounts to be proven at the time of trial; for all of Plaintiff s actual costs and attorneys fees pursuant to RCW. et seq. and RCW.0 et. seq. and Olympic Steamship and its progeny, and common law; for treble damages including the damages determined by the B.C. UMP arbitration, pursuant to RCW. et seq. and RCW.0 et seq.; pre-judgment interest on all special damages; post judgment interest of 1% per annum; and for such other costs and further relief as the Court may deem just and equitable. RESPECTFULLY SUBMITTED this day of May,. W. Mark Belanger, WSBA #0 Greg Samuels, WSBA # Attorneys for Plaintiff COMPLAINT - 0 WEST ND AVENUE # (0) -

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