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DocuMENT PREPARED 

ON RECYCLED PAPER 

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 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-P JH 

DECLARATION OF SUMERA KHAN 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: 9:00 a.m. 

Ctrm: 3 

Complaint Filed: February 7, 2017 

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

DECLARATION OF SUMERA KHAN 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 1 of 21
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DocUMENT PREPARED 

ON RECYCLED PAPER 

I, Sumera Khan, hereby say and declare as follows: 

1. I am an attorney duly admitted to practice law in the state of Texas and am an 

Associate with the law firm ofNorton Rose Fulbright US, LLP, counsel of record for Defendants 

HCC Life Insurance Company and HCC Medical Insurance Services, LLC (erroneously sued as 

Tokio Marine HCC- Medical Insurance Services Group) ("HCC") in this matter. 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. Plaintiff Mohammed Azad alleges at paragraph 19 of the Class Action Complaint 

("Complaint") that, in connection with his purchase of his short-term insurance policy on or about 

December 8, 2015, he was directed to the Insurance Care Direct website, located at 

www.insurancecaredirect.com. 

3. Exhibit 1 is a screenshot of the "Short Term Insurance" page, as was linked in 

December 2015 from that website's homepage that disclosed that short term policies "are 

generally for the healthy as pre-existing conditions are not covered." This screenshot was taken 

from the Archive.org site (also known as Way Back Machine). 

4. I contacted Ubiquis, a transcription service, and provided to Ubiquis the audio 

recording manually filed as Exhibit A to the Declaration of Dan Garavuso and referenced at 

paragraphs 20 and 21 of the Complaint. Exhibit 2 is a true and correct copy of a transcription 

Ubiquis prepared of that recording that includes a certificate by the transcriber affirming that the 

"transcript was prepared using electronic transcription equipment and is a true and accurate 

record to the best of [her] ability." 

II 

II 

II 

II 

II 

II 

II 

- 1 -

DECLARATION OF SUMERA KHAN 

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

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 2 of 21
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0c:o;Mt-N'T rJu'"..PARt-D 

ON R£C'YCLED PArER 

5. Certain of the declarations and exhibits submitted by HCC in support of their 

motion to dismiss and their alternative motion to strike contain redactions of personal or health 

information in accordance with Fed. R. Civ. P. 5.2 and the Health Insurance Portability and 

Accountability Act of 1996 ("HIPAA''). 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of pe1jury that the foregoing is true 

and correct. Executed this 13th day of April, 2017, at Houston, Texas. 

a Khan 

2821 1240. 1 - 2 -

DECLARATION OF SUM ERA KHAN 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 3 of 21
EXHIBIT 1 

! . 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 4 of 21
Exhibit 

Step One:

Step Two:

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 5 of 21
EXHIBIT 2 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 6 of 21
AZAD MOHAMMED 20151208

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 7 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

2

2 [START RECORDING 

3 AZAD_MOHOMMED_20151208_HFLEX] 

4 MR. VERNON MONTGOMERY: Hi, my name is Vernon 

5 Montgomery, and I am a representative in the 

6 verification department. And this verification 

7 number is HCCHFVH0012082015. Today’s date is 

8 December 8, 2015. This call is being recorded for 

9 quality assurance. This call will confirm that you

10 do understand that you’re purchasing a short-term 

11 medical plan, underwritten by HCC Life Insurance 

12 Company, and administered by Health Insurance 

13 Innovations, which will provide a six-month term of

14 major medical insurance, and that your agent of 

15 record is Mr., excuse me, is Ms. Melady Martin, at 

16 Insurance Care Direct. Okay? 

17 MR. AZAD: Okay. 

18 MR. MONTGOMERY: Now Mr. Azad, you understand that 

19 short-term medical insurance is not considered 

20 minimal essential coverage under the Affordable Care 

21 Act and therefore, which is also known as Obamacare. 

22 And that you may be subject to a tax penalty, 

23 correct? 

24 MR. AZAD: Yes. 

25 MR. MONTGOMERY: You understand that the insurance 

26 does not pay benefits for the first 12 months of 

27 coverage, for conditions for which medical advice, 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 8 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

3

2 care, diagnosis, treatment, consultation, or 

3 medication which is recommended by or received from

4 a doctor within five years immediately preceding the 

5 coverage effective date. If you have a condition 

6 that has manifested itself, or shows signs of 

7 symptoms where a reasonable prudent person would 

8 seek medical attention, it would be considered pre9 existing regardless of whether you have been 

10 diagnosed or treated for the condition previously. 

11 This limitation may vary by state and does not apply 

12 to prescription discount benefit, correct? 

13 MR. AZAD: Correct. 

14 MR. MONTGOMERY: Now please state your full name and 

15 address for the recording. 

16 MR. AZAD: Mohammed J. Azad. I'm at 27781 Dickins 

17 Ave., Hayward, California, 94544. 

18 MR. MONTGOMERY: Thank you. Now Mr. Azad, these 

19 questions are for all proposed insureds. Please 

20 respond to each question. I would like to verify 

21 your understanding of your insurance purchase. You

22 understand that the insurance program is a short23 term medical insurance plan, that coverage is non24 renewable, and it will terminate at the end of the 

25 coverage period, right? 

26 MR. AZAD: Right. 

27 MR. MONTGOMERY: You understand that if you had a 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 9 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

4

2 prior short-term medical plan with HCC Life 

3 Insurance Company, you must qualify under a new 

4 application for insurance to get eligible for a new

5 short-term medical plan. You understand that if you 

6 are deemed eligible, your new short-term medical 

7 plan will have a new effective date, new pre8 existing conditions limitation, new deductibles, and 

9 new co-insurance limits. You do understand this, 

10 correct? 

11 MR. AZAD: Yes. 

12 MR. MONTGOMERY: All righty. You understand, now I

13 do have some medical questions to go over. These 

14 medical questions apply to all family members 

15 applying for coverage. You do understand that if 

16 you falsify or neglect to answer any questions 

17 accurately, this will nullify the application and 

18 void all benefits of the policy. You do understand

19 this, correct? 

20 MR. AZAD: Yes, yes. 

21 MR. MONTGOMERY: All righty, will any applicant have 

22 other health insurance enforced on the policy 

23 effective date or be eligible for Medicaid? 

24 MR. AZAD: No. 

25 MR. MONTGOMERY: Are you or any applicant now 

26 pregnant, an expectant father, in process of 

27 adoption, or undergoing infertility treatment? 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 10 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

5

2 MR. AZAD: No. 

3 MR. MONTGOMERY: Over 300 lbs., if male, or over 250 

4 lbs., if female? 

5 MR. AZAD: No. 

6 MR. MONTGOMERY: Within the last five years, has any 

7 applicant been diagnosed, treated, taken medication, 

8 experienced signs of symptoms of any of the 

9 following: cancer or tumor, stroke, heart disease, 

10 including heart attack, chest pain, or had heart 

11 surgery? 

12 MR. AZAD: No. 

13 MR. MONTGOMERY: Chronic obstructive pulmonary 

14 disease or emphysema, Crohn's disease, liver 

15 disorder, degenerated disk disease, or herniation 

16 bulge? 

17 MR. AZAD: No. 

18 MR. MONTGOMERY: Rheumatoid arthritis, kidney 

19 disorder, diabetes, degenerative joint disease of 

20 the knee? 

21 MR. AZAD: No. 

22 MR. MONTGOMERY: Alcohol abuse, chemical dependency, 

23 or any neurological disorder? 

24 MR. AZAD: No. 

25 NR. MONTGOMERY: Within the last five years, has any 

26 applicant been treated, taken medication, by a 

27 physician or medical practitioner, for AIDS, or 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 11 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

6

2 tested positive for HIV? 

3 MR. AZAD: No. 

4 MR. MONTGOMERY: Are you a US citizen, sir? 

5 MR. AZAD: Yes. 

6 MR. MONTGOMERY: And do you plan to stay in the U.S. 

7 legally as long as you have this policy? 

8 MR. AZAD: Yes. 

9 MR. MONTGOMERY: Your policy includes $50 co-pays 

10 for urgent care center visits for illness or injury, 

11 per person. After the $50 co-payment, the co12 insurance will apply. This benefit is not subject 

13 to the deductible. Doctor office visits are subject 

14 to the deductible and co-insurance. Your plan also

15 includes a per cause deductible of $2,500.00. Your

16 co-insurance will be 80/20, of $20,000. Then the 

17 insurance company pays 100%, up to $100,000. You do 

18 understand this, correct? 

19 MR. AZAD: Yes. 

20 MR. MONTGOMERY: All righty. You have requested 

21 that your insurance become effective on December 9,

22 2015. Is this correct? 

23 MR. AZAD: Yes. 

24 MR. MONTGOMERY: You understand that accidents or 

25 injuries that occur on or after your effective date

26 are covered on the effective date of your insurance

27 coverage. Injuries that occur prior to your 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 12 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

7

2 effective date are excluded. You understand that 

3 treatments for sickness are not covered until at 

4 least 72 hours after the effective date. The 

5 waiting period for sickness may not apply in your 

6 state, okay? 

7 MR. AZAD: Yes. 

8 MR. MONTGOMERY: You understand this policy does not 

9 pay for benefits or expenses from any of the 

10 following: routine medical examinations, such as 

11 physicals or immunizations; prescription drugs; 

12 obesity; maternity or well baby care; non-medically

13 necessary care; expenses that are not usual and 

14 customary. Please refer to your policy for a 

15 complete listing of limitations and exclusions, 

16 security and privacy disclaimers which can be found

17 by logging into your account at www.hiiquote.com. 

18 AS part of your membership, you will also receive 

19 prescription discounts benefits. Agile Discount Rx

20 will allow you to save an average of 46% with 

21 potential savings of up to 75% at more than 60,000 

22 pharmacies nationwide. This card can be used for 

23 your entire family, including pets, and it never 

24 expires. Discounts are available exclusively 

25 through participating pharmacies and providers. The 

26 range of the discounts will vary depending on the 

27 type of provider and services rendered. This 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 13 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

8

2 program does not make payments directly to 

3 providers. Members are required to pay for all 

4 healthcare services. Pharmacy locator and 

5 prescription drug lookup is available at 

6 www.myfreerxcard.com. This benefit is not 

7 affiliated with HCC Life Insurance Company. Please

8 review your policy and certificate for a list of any 

9 exclusions, limitations, and acknowledgements 

10 specific to your state, okay? 

11 MR. AZAD: Okay. 

12 MR. MONTGOMERY: Now, included in the monthly plan 

13 cost is the TelaDoc benefits. Now with TelaDoc, you 

14 have access to a national network of board-certified 

15 physicians who provide diagnostic consultations via

16 telephone 24 hours a day, 365 days a year. There’s

17 a one-time registration cost of $10 required before

18 the first consultation. All future calls are 

19 guaranteed within one hour and that consultation is

20 at no cost to you. Every participant is given a 

21 username and access to their TelaDoc fulfillment 

22 document online. TelaDoc is not a part of the 

23 insurance plan, nor is it affiliated with the 

24 insurance company. Also included is the value 

25 benefits package. You shall receive many benefits 

26 such as the Kare 360 Patient Advocacy Program, 24/7

27 nurse line, roadside assistance, Lens Crafter vision 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 14 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

9

2 club, Office Depot discounts, UPS discounts, and car 

3 rental discounts, correct? 

4 MR. AZAD: Correct. 

5 MR. MONTGOMERY: Also included is the Chiro and 

6 Podiatry Care Plus package. It is a discount 

7 medical plan that allows you access to the Choose 

8 Healthy program, which utilizes a network of more 

9 than 28,000 credentialed health care providers, 

10 including 20,000 chiropractors. Members receive 25% 

11 off normal fees and services. The plan also 

12 provides you access to Healthcare Networks of 

13 America podiatry services. Member receive savings 

14 of 20-50% on the providers' normal fees. 

15 Additionally, you will receive discounts on lab 

16 tests, diagnostic imaging, vitamins and supplements, 

17 and popular brand name pet meds, correct? 

18 MR. AZAD: Correct. 

19 MR. MONTGOMERY: Also included, is the benefits of 

20 PEP. PEP is an online personal health and wellness

21 program designed to help members achieve goals 

22 regardless of age, let me see here, regardless of 

23 age, gender, or level of fitness. PEP offers 

24 members access to health calculators for easy 

25 tracking and self-assessments, health information 

26 from professional staff, daily health tips on 

27 nutrition, weight loss, exercise, disease 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 15 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

10

2 prevention, as well as the ability to obtain the 

3 same co-workouts used by many professional athletes. 

4 You understand there is a $125 one-time cost for PEP 

5 services, correct? 

6 MR. AZAD: Correct. 

7 MR. MONTGOMERY: That brings your first month’s 

8 total to, no, excuse me, you have also agreed to 

9 purchase the Cigna Dental access network access plan 

10 offered by Cigna Dental and administered by Health 

11 Insurance Innovations for a monthly cost of $23, is

12 this correct? 

13 MR. AZAD: Yes. 

14 MR. MONTGOMERY: So, you understand that Cigna's 

15 Dental network access plan is not dental insurance. 

16 It is a discount dental program that provides 

17 members access to discounted fees, pursuant to DPPOP 

18 schedules negotiated by Cigna Dental with a 

19 participating dentist. Members are responsible for

20 paying all charges directly to participating 

21 dentists at the time services are rendered. Cigna 

22 Dental discounts average 35% nationwide when 

23 compared to average area charges. These discounts 

24 depend upon procedure codes, geographic location, 

25 and the Cigna Dental contracted rate agreed upon 

26 with the dentist or dentist specialist, correct? 

27 MR. AZAD: Yes. 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 16 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

11

2 MR. MONTGOMERY: You understand that you must visit

3 a participating provider of Cigna Dental network 

4 access to receive a discounted fee. You must 

5 present a Cigna Dental ID card when visiting a Cigna 

6 Dental provider. If not, the discounted rate will 

7 not apply, and you may be charged as usual and 

8 customary fee. Okay? 

9 MR. AZAD: Okay. 

10 MR. MONTGOMERY: Now, that brings your first month’s 

11 total to $336.56, and only $211.56 for each month 

12 after that. This will be billed today through your

13 Visa card, the last four digits of that card number

14 ending in 6645. The expiration date of that card, 

15 06/18, is this correct? 

16 MR. AZAD: Yes. 

17 MR. MONTGOMERY: You understand that your first 

18 payment will be processed today. You will see that

19 payment withdrawn within the next 24 hours, and your 

20 plan will become effective on December 9, 2015. You 

21 also understand that your next month’s payment and 

22 recurring monthly payments after will be 

automatically processed from the account on the 9th 23 

24 of each month thereafter for the term of the 

25 coverage. You understand that if you cancel your 

26 insurance, or if we are unable to take your payment

27 on the billing date, your insurance and benefits 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 17 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

12

2 will be canceled. No representation by an agent, or 

3 any other person shall be binding on Health 

4 Insurance Innovations, or HCC Life Insurance 

5 Company. You do understand this, correct? 

6 MR. AZAD: Yes. 

7 MR. MONTGOMERY: An email will be sent to the email

8 address you provided, giving you the ability to 

9 print or save the application for insurance, ID 

10 cards, insurance certificates, scheduled benefits, 

11 and any other state or company forms. You will also 

12 receive within the next seven to ten business days a 

13 copy of the welcome letter and ID cards in the mail. 

14 Please make sure to read your policy benefits, 

15 limitations and exclusions within your ten-day free16 look period. You can access your policy online at 

17 www.hiiquote.com or call customer service if you do

18 not have access to a computer. If you have any 

19 questions at any time please call HII Member 

20 Services at the number (877)376-5831. You do 

21 understand this, correct? 

22 MR. AZAD: Yes. 

23 MR. MONTGOMERY: Now this is a notice of voice 

24 consent to electronic transactions, signatures, and

25 the documents. You consent the use to electronic 

26 signatures of the documents which would otherwise 

27 only be valid if they are in writing. We want to 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 18 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

13

2 confirm that you agree to the completion of your 

3 application for the insurance plan and any 

4 applicable benefit programs over the telephone. And 

5 that the plan benefits, legal notices, and costs of

6 the insurance were reviewed with you. You agree 

7 that your voice consent will serve as your 

8 signature, correct? 

9 MR. AZAD: Yes. 

10 MR. MONTGOMERY: You understand that Health 

11 Insurance Innovations on behalf of its partners will 

12 rely on your signature as consent to receive the 

13 documents electronically, unless you revoke this 

14 consent. You can update your information or revoke

15 this consent at any time by calling HII at the 

16 number (877)376-5831, or emailing 

17 support@hiiquote.com. If you decide to withdraw 

18 your consent, the legal validity and enforceability

19 of electronic transactions and signatures used prior 

20 to withdrawal will not be affected. You may request 

21 specific documents in paper forms at any time 

22 without revoking this consent. You agree to review

23 the application produced by the voice signature 

24 carefully to ensure your full understanding of all 

25 provisions of the coverage. If you are in agreement 

26 with this consent, please say yes. 

27 MR. AZAD: Yes. 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 19 of 21
1 AZAD MOHAMMED 20151208

Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

14

2 MR. MONTGOMERY: Now, just for your protection Mr. 

3 Azad, just so I can confirm your understanding and 

4 agreement to the terms and conditions of this 

5 policy, please verify that by saying yes. 

6 MR. AZAD: Yes. 

7 MR. MONTGOMERY: Thank you. That does complete this 

8 verification. 

9 [END RECORDING] 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 20 of 21
Ubiqus 

61 Broadway – Suite 1400 – New York, NY 10006 

Phone: 212-346-6666 * Fax: 888-412-3655 

15

C E R T I F I C A T E 

I, Kaitlyn Wagstaff certify that the foregoing 

transcript of Azad, Mohammed, was prepared using 

standard electronic transcription equipment and is a 

true and accurate record to the best of my ability.

I further certify that I am not connected by blood,

marriage or employment with any of the parties 

herein nor interested directly or indirectly in the

matter transcribed. 

Signature 

Date ________March 28, 2017 ________ 

Case 4:17-cv-00618-PJH Document 50 Filed 04/13/17 Page 21 of 21