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Do.:Ll}v[ENT P~P ARED 

ON RE:::YC LEQ PAFER 

GERARD G. PECHT (Admitted Pro Hac Vice) 

gerard. pecht@nortonrosefulbright. com 

NORTON ROSE FULBRIGHT US LLP 

1301 McKinney, Suite 5100 

Houston, Texas 770 1 0-3 09 5 

Telephone: (713) 651-5151 

Facsimile: (713) 651-5246 

M. SCOTT INCERTO (Admitted Pro Hac Vice) 

scott. incerto@nortonroseful bright. com 

NORTON ROSE FULBRIGHT US LLP 

98 San Jacinto Boulevard, Suite 1100 

Austin, Texas 78701-4255 

Telephone: (512) 474-5201 

Facsimile: (512) 536-4598 

JOSHUA D. LICHTMAN (SBN 176143) 

joshua.li chtman@nortonrosefulbright. com 

MICHELLE L. MELLO (SBN 288081) 

michelle. mello@nortonrosefulbright. com 

NORTON ROSE FULBRIGHT US LLP 

555 South Flower Street, Forty-First Floor 

Los Angeles, California 90071 

Telephone: (213) 892-9200 

Facsimile: (213) 892-9494 

Attorneys for Defendants 

HCC LIFE INSURANCE COMPANY and HCC 

MEDICAL INSURANCE SERVICES, LLC 

(erroneously sued as TOKIO MARINE HCC -

MEDICAL INSURANCE SERVICES GROUP) 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA- OAKLAND DIVISION 

MOHAMMED AZAD and DANIELLE 

BUCKLEY, on behalf of themselves and all 

others similarly situated, 

Plaintiffs, 

v. 

TOKIO MARINE HCC- MEDICAL 

INSURANCE SERVICES GROUP, HEALTH 

INSURANCE INNOVATIONS, INC. , HCC 

LIFE INSURANCE COMPANY, and 

CONSUMER BENEFITS OF AMERICA, 

Defendants. 

Case No.: 4:17-cv-00618-PJH 

DECLARATION OF DAN GARA VUSO 

IN SUPPORT OF HCC LIFE 

INSURANCE COMPANY AND HCC 

MEDICAL INSURANCE SERVICES, 

LLC'S MOTION TO DISMISS AND 

THEIR ALTERNATIVE MOTION TO 

STRIKE CLASS ALLEGATIONS 

Date: May 24, 2017 

Time: 9:00a.m. 

Ctrm: 3 

Complaint Filed: February 7, 2017 

Case No.: 4: 17-cv-00618-P.JH 

DECLARATION OF DAN GARA VUSO 

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 1 of 8
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D:xtTJ'.{EN'T PREP AFED 

ON RB:'!Cl.ED PAPER 

I, Dan Garavuso, hereby say and declare as follows: 

l . I am Vice President of Compliance at Health Insurance Innovations, Inc. ("HII"). 

I have worked with HII since August 2012 and have been recently appointed to my current 

position. During the relevant time period for this case, HII was a duly licensed and appointed 

insurance producer for HCC Medical Insurance Service, LLC ("HCC") and was authorized to 

market and sell HCC Short-Term Medical insurance policies. In my capacity as Vice President of 

Compliance, I am knowledgeable about the verification call and welcome email process. I have 

personal knowledge of the matters set forth in this declaration and, if called as a witness, I could 

and would testify competently thereto. 

2. Manually filed herewith as Exhibit A is a true and correct copy of the recording of 

plaintiff Mohammed Azad's ("Azad") insurance application verification telephone call, dated 

December 8, 2015, and referenced at paragraphs 20 and 21 of the Class Action Complaint 

("Complaint"), that HII received from the independent agency selling the policy and that has been 

kept by HII in the ordinary and regular course of business. 

3. Attached hereto as Exhibit B is a true and correct copy of an email confirming 

Azad's coverage, which was sent from HII to Azad on December 8, 2015, and is referenced at 

paragraph 22 of the Complaint. 

4. The email states "to learn more about how your plan works, click here," which 

includes a hyperlink to an HCC one and a half minute video, manually filed as Exhibit 14 to the 

Declaration of Jon Padgett. 

Pursuant to 28 U.S. C. § 17 46, I declare under penalty of perjury that the foregoing is true 

and correct. Executed this 13th day of April, 2017, at Tampa, Florida. 

- 1 - Case No.: 4: 17-cv-00618-P.JH 

DECLARATION OF DANG ARA VUSO 

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 2 of 8
EXHIBIT A 

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 3 of 8
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Do<..'"\JMfNTPlmrARPJl 

ONRF::'I'(:I.f.D PAP~ 

GERARD G. PECHT (Admitted Pro Hac Vice) 

gerard.pecht@nortonrosefulbright.com 

NORTON ROSE FULBRIGHT US LLP 

1301 McKinney, Suite 5100 

Houston, Texas 77010-3095 

Telephone: (713) 651-5151 

Facsimile: (713) 651-5246 

M. SCOTT INCERTO (Admitted Pro Hac Vice) 

scott.incerto@nortonrosefulbright.com 

NORTON ROSE FULBRIGHT US LLP 

98 San Jacinto Boulevard, Suite 1100 

Austin, Texas 78701-4255 

Telephone: (512) 474-5201 

Facsimile: (512) 536-4598 

JOSHUA D. LICHTMAN (SBN 176143) 

joshua.lichtman@nortonrosefulbright.com 

MICHELLE L. MELLO (SBN 288081) 

michelle.mello@nortonrosefulbright.com 

NORTON ROSE FULBRIGHT US LLP 

555 South Flower Street, Forty-First Floor 

Los Angeles, California 90071 

Telephone: (213) 892-9200 

Facsimile: (213) 892-9494 

Attorneys for Defendants 

HCC LIFE INSURANCE COMPANY and HCC 

MEDICAL INSURANCE SERVICES, LLC 

(erroneously sued as TOKIO MARINE HCC -

MEDICAL INSURANCE SERVICES GROUP) 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA- OAKLAND DIVISION 

MOHAMMED AZAD and DANIELL£ 

BUCKLEY, on behalf of themselves and all 

others similarly situated, 

Plaintiffs, 

v. 

TOKIO MARINE HCC- MEDICAL 

INSURANCE SERVICES GROUP, HEALTH 

INSURANCE INNOVATIONS, INC., HCC 

LIFE INSURANCE COMPANY, and 

CONSUMER BENEFITS OF AMERICA, 

Defendants. 

Case No.: 4: 17-cv-00618-PJH 

MANUAL FILING NOTIFICATION 

Date: May 24, 2017 

Time: 9:00 a.m. 

Ctrm: 3 

Complaint Filed: February 7, 2017 

Case No.: 4:17-cv-00618-PJH 

MANUAL FILING NOTIFICA TJON 

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 4 of 8
Regarding: EXIDBfT A to the DECLARA TlON OF DAN GARA VUSO 

2 This filing is in paper Qr physical form only, and is being maintained in the case file in the 

3 Clerk's office. lfyou are a participant on this case, this filing will be served in hard-copy shortly. 

4 For information on retrieving this filing directly from the court, please see the court's main 

5 website at http://www.cand.uscourts.gov under Frequently Asked Questions (FAQ). 

6 This filing was not efiled for the following reason(s): 

7 Unable to Scan Documents 

8 _Physical Object (please describe):-------------

9 ...x_ Non-Graphicffext Computer File (audio, video, etc.) on CD or other media 

10 Item Under Seal in Criminal Case 

11 _Conformance with the Judicial Conference Privacy Policy (General Order 53) 

12 _Other (please describe):----------- ------

l3 

14 Dated: April 14, 2017 

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GERARD G. PECIIT 

M. SCOTT INCERTO 

JOSHUA D. LICHTMAN 

MICHELLE L. MELLO 

NORTON ROSE FULBRIGHT US LLP 

By Is! Joshua D. Lichtman 

JOSHUA D. LICHTMAN 

Attorneys for Defendants 

HCC LIFE INSURANCE COMPANY and 

HCC MEDICAL INSURANCE SERVICES, 

LLC (erroneously sued as TOKIO MARINE 

HCC- MEDICAL INSURANCE SERVICES 

GROUP) 

- 1 - Case No.: 4:17-cv-00618-PJH 

MANUAL FILING NOTIFICATION 

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 5 of 8
EXIIIBIT B 

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 6 of 8
Address Type Email Status Reason Date 

To delivered 12-08-2015 

CC renee@insurancecaredirect.com delivered 12-08-2015 

CC teller@insurancecaredirect.com delivered 12-08-2015 

BCC dgaravuso@hiiquote.com delivered 12-08-2015 

Dear MOHOMMED AZAD,

Thank you for applying. We received your request for coverage under the following plans:

HealtheMed STM with an effective date of 12/09/2015. Amount paid: $188.56

Cigna Dental Network Access with an effective date of 01/01/2016. Amount paid: $23.00

Once your application is approved and your initial payment of $336.56 is processed, your 

coverage and benefits will begin on the corresponding effective date shown above.

Please note that each policy above is billed separately. if one policy terminates or is 

canceled, it will not automatically cancel your other policies, unless requested by you.

View and Download Your 

Benefits

10-day Free Look

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 7 of 8
All of your important insurance 

information is available for you to view, 

download and print at 

HIIInsuranceSolutions.com.

We have created a user ID and password 

for you, so you can login immediately, 

print your ID cards and view details about 

your coverage.

We want you to be happy with your 

coverage. If you are not satisfied for any 

reason and no claims have been filed, you 

may cancel your plan within 10 calendar 

days of your effective date to receive a full 

refund. The refund will include your first 

payment and application fee.

Member ID:

User ID:

Password:

For your security, please update your 

password after logging in.

You will also receive a welcome letter in 7-

10 business days that includes your 

insurance ID card and more information 

about your new plan and benefits.

Learn More

To learn more about how your plan works,

click here

Questions?

Billing Questions

1.855.221.5852

Monday - Friday 8:30am to 7:00pm EST

support@hiiinsurancesolutions.com

Benefits & Claims Services

HCC Medical Insurance Services

1.800.605.2282

Case 4:17-cv-00618-PJH Document 51 Filed 04/13/17 Page 8 of 8