EXHIBIT “A”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 1 of 33
MTrHARL. K. FANES 

L! erg. of the SuPerior Court 

By Angus McLoone, Deputy 

Date 09/15/201? Time 16:38:42 

Description 

 CASE# CV2017-054614 

CIVIL NEW COMPLAINT 372.00 W 

--------------------------- 

TOTAL AMOUNT 

Race pt 26160881 

Amount 

0.00 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com 

Attorneys for Maricopa County Special Health Care District 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTY SPECIAL 

HEALTH CARE DISTRICT, a body 

politic, governing body for and doing 

business as MARICOPA INTEGRATED 

HEALTH SYSTEM, 

No. MO 7 -054614 

COMPLAINT 

Plaintiff, 

(Breach of Contract; Breach of Duty of Good Faith 

v. and Fair Dealing; Insurance Bad Faith; Declaratory 

Relief) 

LEXINGTON INSURANCE COMPANY, 

a foreign capital stock insurance company, 

and AIG CLAIMS, INC., a foreign 

corporation, ABC CORPORATIONS, 

XYZ PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

Defendants. 

COMES NOW Plaintiff Maricopa County Special Health Care District, a governmental entity 

also referred to as Maricopa Integrated Health System (the "District") and by and through counsel 

undersigned for its Complaint against the Defendants alleges and states as follows: 

PARTIES 

1. Maricopa County Special Health Care District is a governmental body also known as Maricopa 

Integrated Health System. 

2. Lexington Insurance Company (hereinafter "Lexington") is a foreign capital stock insurance 

MTrHARL. K. FANES 

L! erg. of the SuPerior Court 

By Angus McLoone, Deputy 

Date 09/15/201? Time 16:38:42 

Description 

 CASE# CV2017-054614 

CIVIL NEW COMPLAINT 372.00 W 

--------------------------- 

TOTAL AMOUNT 

Race pt 26160881 

Amount 

0.00 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com 

Attorneys for Maricopa County Special Health Care District 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTY SPECIAL 

HEALTH CARE DISTRICT, a body 

politic, governing body for and doing 

business as MARICOPA INTEGRATED 

HEALTH SYSTEM, 

No. MO 7 -054614 

COMPLAINT 

Plaintiff, 

(Breach of Contract; Breach of Duty of Good Faith 

v. and Fair Dealing; Insurance Bad Faith; Declaratory 

Relief) 

LEXINGTON INSURANCE COMPANY, 

a foreign capital stock insurance company, 

and AIG CLAIMS, INC., a foreign 

corporation, ABC CORPORATIONS, 

XYZ PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

Defendants. 

COMES NOW Plaintiff Maricopa County Special Health Care District, a governmental entity 

also referred to as Maricopa Integrated Health System (the "District") and by and through counsel 

undersigned for its Complaint against the Defendants alleges and states as follows: 

PARTIES 

1. Maricopa County Special Health Care District is a governmental body also known as Maricopa 

Integrated Health System. 

2. Lexington Insurance Company (hereinafter "Lexington") is a foreign capital stock insurance 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 2 of 33
company transacting business within the State of Arizona, County of Maricopa. 

3. AIG Claims Services, Inc. is a foreign corporation that transacts the business of insurance claims 

administration within the State of Arizona, County of Maricopa. 

4. The individuals and entities fictitiously identified as Defendants herein (designated as Doe, ABC 

Corporations and XYZ Partnerships) are deemed to be affiliates of or subsidiaries of the above-named 

Defendants, and/or any and all individuals or entities who may be liable for the acts alleged hereinafter. 

JURISDICTION AND VENUE 

5. This court has jurisdiction over the subject matter and parties involved herein. 

• GENERAL ALLEGATIONS 

6. At all times alleged hereinafter, Plaintiff was a named insured under a policy of insurance 

bearing Policy No. 6793282 (the "Policy") issued by Defendant Lexington which policy provided excess 

healthcare professional liability coverage on a claims-made basis. 

7. A justiciable controversy exists between Plaintiffs and Defendants because a dispute has arisen 

regarding coverage for the amounts for which the District has become legally obligated to pay (and has 

now in fact paid) to the Orosco Plaintiffs as set forth herein. 

8. On or about March 6, 2012, a Complaint was filed in Maricopa County Superior Court by 

Plaintiffs Brandon and Jennifer Orosco individually and on behalf of their children, Kaylen, Marissa and 

Silas Orosco alleging that Brandon Orosco suffered injuries as a result of acts or omissions committed 

while he was in the care of Maricopa County Special Health Care DistriCt and its employees, physicians 

and/or staff members for which the Orosco Plaintiffs sought recovery of damages related to medical 

expenses, pain, suffering, disfigurement, impairment and diminished earning capacity. 

9. At all times material to the allegations set forth herein, the District had a retained limit with 

regard to underlying insurance in the amount of $5 million, which amount was subject to erosion by any 

and all indemnity or defense expense incurred. 

10. At all material times, Defendants Lexington and AIG were aware of the pending Orosco Action, 

and in fact monitored and audited the District's defense of that matter. 

-2- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

company transacting business within the State of Arizona, County of Maricopa. 

3. AIG Claims Services, Inc. is a foreign corporation that transacts the business of insurance claims 

administration within the State of Arizona, County of Maricopa. 

4. The individuals and entities fictitiously identified as Defendants herein (designated as Doe, ABC 

Corporations and XYZ Partnerships) are deemed to be affiliates of or subsidiaries of the above-named 

Defendants, and/or any and all individuals or entities who may be liable for the acts alleged hereinafter. 

JURISDICTION AND VENUE 

5. This court has jurisdiction over the subject matter and parties involved herein. 

• GENERAL ALLEGATIONS 

6. At all times alleged hereinafter, Plaintiff was a named insured under a policy of insurance 

bearing Policy No. 6793282 (the "Policy") issued by Defendant Lexington which policy provided excess 

healthcare professional liability coverage on a claims-made basis. 

7. A justiciable controversy exists between Plaintiffs and Defendants because a dispute has arisen 

regarding coverage for the amounts for which the District has become legally obligated to pay (and has 

now in fact paid) to the Orosco Plaintiffs as set forth herein. 

8. On or about March 6, 2012, a Complaint was filed in Maricopa County Superior Court by 

Plaintiffs Brandon and Jennifer Orosco individually and on behalf of their children, Kaylen, Marissa and 

Silas Orosco alleging that Brandon Orosco suffered injuries as a result of acts or omissions committed 

while he was in the care of Maricopa County Special Health Care DistriCt and its employees, physicians 

and/or staff members for which the Orosco Plaintiffs sought recovery of damages related to medical 

expenses, pain, suffering, disfigurement, impairment and diminished earning capacity. 

9. At all times material to the allegations set forth herein, the District had a retained limit with 

regard to underlying insurance in the amount of $5 million, which amount was subject to erosion by any 

and all indemnity or defense expense incurred. 

10. At all material times, Defendants Lexington and AIG were aware of the pending Orosco Action, 

and in fact monitored and audited the District's defense of that matter. 

-2- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 3 of 33
11. According to the Schedule of Underlying Insurance, Lexington specified that the healthcare 

professional liability limits of $5 million with regard to the self-insured retention were subject to erosion 

for "expenses and indemnity." 

12. Nowhere within the policy authored by Lexington is the term "expenses" defined as it relates to 

erosion of the SIR. 

13. Nowhere within the policy authored by Lexington is the term "indemnity" defined with regard to 

erosion of the SIR. 

14. Attached to and incorporated within the Policy of insurance issued by Lexington is a series of 

forms, which includes form Endorsement No. 9, which endorsement served to delete exclusionary 

language that would have purported to exclude coverage for, "punitive, exemplary, multiplied damages 

or the multiple portion of multiple damages." 

15. The effect of Endorsement No. 9 was to vest the insured with coverage for "punitive, exemplary, 

multiplied damages or the multiple portion of multiple damages" that might have otherwise been 

excluded from coverage. 

16. The only remaining language after the application of Endorsement No. 9 served to exclude 

coverage for "fines or penalties". 

17. Nowhere within the Policy authored by Lexington is there a definition of "fines". 

18. Nowhere within the Policy authored by Lexington Insurance is a definition of the word 

"penalties". 

19. The Policy does not exclude coverage for sanctions. 

20. Neither "fines" nor "penalties" is a capitalized or legally significant or defined term. 

21. On or about March 6, 2012, the Orosco Plaintiffs filed a Complaint and related documents 

stating a claim against the District and others resulting in the District incurring costs, attorneys' fees, 

litigation expenses, expert witness fees and various forms of "expense" as that term is interpreted with 

regard to erosion of the SIR in an amount exceeding $590,921.35 payable to third parties and incurred 

internal legal fees in an amount to be proven at trial. 

-3- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

11. According to the Schedule of Underlying Insurance, Lexington specified that the healthcare 

professional liability limits of $5 million with regard to the self-insured retention were subject to erosion 

for "expenses and indemnity." 

12. Nowhere within the policy authored by Lexington is the term "expenses" defined as it relates to 

erosion of the SIR. 

13. Nowhere within the policy authored by Lexington is the term "indemnity" defined with regard to 

erosion of the SIR. 

14. Attached to and incorporated within the Policy of insurance issued by Lexington is a series of 

forms, which includes form Endorsement No. 9, which endorsement served to delete exclusionary 

language that would have purported to exclude coverage for, "punitive, exemplary, multiplied damages 

or the multiple portion of multiple damages." 

15. The effect of Endorsement No. 9 was to vest the insured with coverage for "punitive, exemplary, 

multiplied damages or the multiple portion of multiple damages" that might have otherwise been 

excluded from coverage. 

16. The only remaining language after the application of Endorsement No. 9 served to exclude 

coverage for "fines or penalties". 

17. Nowhere within the Policy authored by Lexington is there a definition of "fines". 

18. Nowhere within the Policy authored by Lexington Insurance is a definition of the word 

"penalties". 

19. The Policy does not exclude coverage for sanctions. 

20. Neither "fines" nor "penalties" is a capitalized or legally significant or defined term. 

21. On or about March 6, 2012, the Orosco Plaintiffs filed a Complaint and related documents 

stating a claim against the District and others resulting in the District incurring costs, attorneys' fees, 

litigation expenses, expert witness fees and various forms of "expense" as that term is interpreted with 

regard to erosion of the SIR in an amount exceeding $590,921.35 payable to third parties and incurred 

internal legal fees in an amount to be proven at trial. 

-3- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 4 of 33
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19. 

20 

21 

22 

23 

24 

25 

26 

'22. In addition to the "expenses" incurred by the District, an "indemnity" payment was made to 

Plaintiffs Orosco in the form of reimbursement of medical expenses owed to the District in the amount 

of $307,630.38. The Policy allows for an offset or erosion of the SIR with regard to indemnity 

payments (an undefined. term) made by or on behalf of the District; the indemnity payment' to Mr. 

Orosco arises from treatment received by Mr. Orosco during his April 26, 2011 admission for the guide 

wire removal, and for which the District bore the entire cost of $307,630.38 for that hospital admission. 

As a result of briefing on this issue, because the District agreed to bear that expense, the special damages 

claimed by Mr. Orosco (as well as general compensatory damages and the potential aggravation of the 

claim evaluation) inured to the benefit of Lexington, and accordingly the District is entitled to erosion of 

its Policy in a commensurate amount of $307,630.38. 

23. During the pendency of the Orosco Action, the Plaintiffs Orosco filed an Offer of Judgment for 

an amount that was slightly less than the jury verdict ultimately obtained. 

24. On or about November 17, 2014, the Orosco Plaintiffs recovered a jury verdict that was later 

reduced to a judgment against the District in favor of Brandon Orosco in the amount of $3,638,250; in 

favor of Jennifer Orosco in the amount of $495,000; and in favor of each of the Orosco children in-the 

amount of $24,750. 

25. In addition -to the compensatory amounts, the Orosco Plaintiffs recovered a cost judgment 

entered on July 9, 2015 in the total amount of $391,753.55, a portion of which was recoverable by virtue 

of Rule 68 because the verdict ultimately obtained by the Orosco Plaintiffs was slightly more favorable 

than the Offer of Judgment filed by Plaintiffs Orosco in advance of trial. 

26. On or about August 3, 2015, the District filed a timely Notice of Appeal to the Arizona Court of 

Appeals. 

27. At all material times, Lexington was aware of, monitored, and audited the litigation files of the 

District throughout the trial court and appellate matter. 

28. On or about February 2, 2017, the Court of Appeals issued its ruling denying relief to-the District 

with the exception of a nominal issue not pertinent to the relief sought herein. 

-4- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19. 

20 

21 

22 

23 

24 

25 

26 

'22. In addition to the "expenses" incurred by the District, an "indemnity" payment was made to 

Plaintiffs Orosco in the form of reimbursement of medical expenses owed to the District in the amount 

of $307,630.38. The Policy allows for an offset or erosion of the SIR with regard to indemnity 

payments (an undefined. term) made by or on behalf of the District; the indemnity payment' to Mr. 

Orosco arises from treatment received by Mr. Orosco during his April 26, 2011 admission for the guide 

wire removal, and for which the District bore the entire cost of $307,630.38 for that hospital admission. 

As a result of briefing on this issue, because the District agreed to bear that expense, the special damages 

claimed by Mr. Orosco (as well as general compensatory damages and the potential aggravation of the 

claim evaluation) inured to the benefit of Lexington, and accordingly the District is entitled to erosion of 

its Policy in a commensurate amount of $307,630.38. 

23. During the pendency of the Orosco Action, the Plaintiffs Orosco filed an Offer of Judgment for 

an amount that was slightly less than the jury verdict ultimately obtained. 

24. On or about November 17, 2014, the Orosco Plaintiffs recovered a jury verdict that was later 

reduced to a judgment against the District in favor of Brandon Orosco in the amount of $3,638,250; in 

favor of Jennifer Orosco in the amount of $495,000; and in favor of each of the Orosco children in-the 

amount of $24,750. 

25. In addition -to the compensatory amounts, the Orosco Plaintiffs recovered a cost judgment 

entered on July 9, 2015 in the total amount of $391,753.55, a portion of which was recoverable by virtue 

of Rule 68 because the verdict ultimately obtained by the Orosco Plaintiffs was slightly more favorable 

than the Offer of Judgment filed by Plaintiffs Orosco in advance of trial. 

26. On or about August 3, 2015, the District filed a timely Notice of Appeal to the Arizona Court of 

Appeals. 

27. At all material times, Lexington was aware of, monitored, and audited the litigation files of the 

District throughout the trial court and appellate matter. 

28. On or about February 2, 2017, the Court of Appeals issued its ruling denying relief to-the District 

with the exception of a nominal issue not pertinent to the relief sought herein. 

-4- 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 5 of 33
29. In the face of accruing interest on the judgment and after careful consideration, the District made 

the decision to forego filing a Petition for Review to the Supreme Court and secured authority to pay its 

remaining balance, of the SIR and provided notice and the opportunity for Lexington and MG to make 

an election as to whether to pay its respective share in accordance with the calculations regarding 

erosion of the SIR or alternatively pursue further appellate remedies. 

30. At all material times, AIG and Lexington were aware of the status of the appeal; aware of the 

appellate ruling; and ultimately aware of the calculation by the District as to the respective 

responsibilities of the parties, however AIG and Lexington made no response whatsoever until Friday, 

March 3, 2017 (more than two years after the original jury verdict and almost two years following the 

entry of the Cost Judgment), without ever. having issued a reservation of rights or expressing any 

concerns regarding repeated audits and updates with regard to the file relating to defense costs or Rule 

68 recovery, at which time Lexington and AIG denied coverage for the Rule 68 portion of the Judgment 

for the first time alleging that it represented a "penalty", and as such was excluded from coverage, and 

further maintained that $89,686 of the defense costs actually incurred by and paid by the District were 

arbitrarily deemed to be excessive. 

31. Within a matter of days after expressly denying coverage for the Rule 68 portion of the Judgment 

alleging that it represented a "penalty" despite the fact that "penalty" is not defined within the Policy 

and after alleging that $89,686 of the defense costs were excessive, that number dropped to $70,048.30. 

32. Lexington/AIG refused to reconsider its position regarding the alleged `!penalty" exclusion, 

resulting in the District's inability to move forward with satisfying the Judgment because it had relied 

upon the accounting provided to Lexington, which had never been the subject of dispute or reservation. 

33. At all material times, Defendants knew or should have known that to be enforceable, an 

exclusion in an insurance policy must be both "conspicuous" and "phrased in clear language". 

34. At all material times, the Defendants knew or should have known that Arizona law does not 

allow for the enforcement of an ambiguous exclusion. 

35. At all material times, the Defendants knew or should have known that other courts have 

-5- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

29. In the face of accruing interest on the judgment and after careful consideration, the District made 

the decision to forego filing a Petition for Review to the Supreme Court and secured authority to pay its 

remaining balance, of the SIR and provided notice and the opportunity for Lexington and MG to make 

an election as to whether to pay its respective share in accordance with the calculations regarding 

erosion of the SIR or alternatively pursue further appellate remedies. 

30. At all material times, AIG and Lexington were aware of the status of the appeal; aware of the 

appellate ruling; and ultimately aware of the calculation by the District as to the respective 

responsibilities of the parties, however AIG and Lexington made no response whatsoever until Friday, 

March 3, 2017 (more than two years after the original jury verdict and almost two years following the 

entry of the Cost Judgment), without ever. having issued a reservation of rights or expressing any 

concerns regarding repeated audits and updates with regard to the file relating to defense costs or Rule 

68 recovery, at which time Lexington and AIG denied coverage for the Rule 68 portion of the Judgment 

for the first time alleging that it represented a "penalty", and as such was excluded from coverage, and 

further maintained that $89,686 of the defense costs actually incurred by and paid by the District were 

arbitrarily deemed to be excessive. 

31. Within a matter of days after expressly denying coverage for the Rule 68 portion of the Judgment 

alleging that it represented a "penalty" despite the fact that "penalty" is not defined within the Policy 

and after alleging that $89,686 of the defense costs were excessive, that number dropped to $70,048.30. 

32. Lexington/AIG refused to reconsider its position regarding the alleged `!penalty" exclusion, 

resulting in the District's inability to move forward with satisfying the Judgment because it had relied 

upon the accounting provided to Lexington, which had never been the subject of dispute or reservation. 

33. At all material times, Defendants knew or should have known that to be enforceable, an 

exclusion in an insurance policy must be both "conspicuous" and "phrased in clear language". 

34. At all material times, the Defendants knew or should have known that Arizona law does not 

allow for the enforcement of an ambiguous exclusion. 

35. At all material times, the Defendants knew or should have known that other courts have 

-5- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 6 of 33
determined that the "penalty" exclusion has been deemed to be vague, ambiguous, and susceptible to 

more than one meaning, and is construed by reasonable insureds to be a fine imposed by and paid to a 

governmental entity often for a matter that is criminal or quasi-criminal in nature. 

36. At all material times, Defendants Lexington and AIG owed a duty of good faith and fair dealing 

toward the Insured. 

COUNT I 

(Breach of Contract) 

(only as to Defendant Lexington) 

37. Plaintiff incorporates by reference each and every preceding allegation as though fully set forth 

herein. 

38. District is an insured under the Policy issued by Defendant Lexington and administered by 

Defendant AIG, and as such was entitled to the rights, benefits and privileges stated within the Policy. 

39. Pursuant to the terms and conditions of the Policy, Defendant Lexington owed a duty to 

indemnify Plaintiff from any loss covered under the terms of the Policy. 

40. Lexington denied coverage to the District and/or disallowed credits toward the erosion of its SIR, 

causing the District to incur losses associated with payment of amounts that should have been paid by 

Lexington under the terms of the Policy. 

41. As a direct and proximate result of Lexington's breach of the Policy, Plaintiff sustained damages 

in an amount to be proven at trial. 

COUNT II 

(Breach of the Covenant of Good Faith and Fair Dealing) 

42. Plaintiff incorporates by reference each and every preceding allegation as though fully set forth 

herein. 

43. Defendant Lexington had a contract with Plaintiff, and incorporated within the terms of that 

contract is an implied covenant of good faith and fair dealing. 

44. Lexington, and AIG acting as an agent for and on behalf of Lexington, breached the duty of good 

faith and fair dealing when it disallowed certain defense costs and attorneys' fees in an arbitrary and 

-6- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13' 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

determined that the "penalty" exclusion has been deemed to be vague, ambiguous, and susceptible to 

more than one meaning, and is construed by reasonable insureds to be a fine imposed by and paid to a 

governmental entity often for a matter that is criminal or quasi-criminal in nature. 

36. At all material times, Defendants Lexington and AIG owed a duty of good faith and fair dealing 

toward the Insured. 

COUNT I 

(Breach of Contract) 

(only as to Defendant Lexington) 

37. Plaintiff incorporates by reference each and every preceding allegation as though fully set forth 

herein. 

38. District is an insured under the Policy issued by Defendant Lexington and administered by 

Defendant AIG, and as such was entitled to the rights, benefits and privileges stated within the Policy. 

39. Pursuant to the terms and conditions of the Policy, Defendant Lexington owed a duty to 

indemnify Plaintiff from any loss covered under the terms of the Policy. 

40. Lexington denied coverage to the District and/or disallowed credits toward the erosion of its SIR, 

causing the District to incur losses associated with payment of amounts that should have been paid by 

Lexington under the terms of the Policy. 

41. As a direct and proximate result of Lexington's breach of the Policy, Plaintiff sustained damages 

in an amount to be proven at trial. 

COUNT II 

(Breach of the Covenant of Good Faith and Fair Dealing) 

42. Plaintiff incorporates by reference each and every preceding allegation as though fully set forth 

herein. 

43. Defendant Lexington had a contract with Plaintiff, and incorporated within the terms of that 

contract is an implied covenant of good faith and fair dealing. 

44. Lexington, and AIG acting as an agent for and on behalf of Lexington, breached the duty of good 

faith and fair dealing when it disallowed certain defense costs and attorneys' fees in an arbitrary and 

-6- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13' 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 7 of 33
capricious fashion (demonstrated by the fact that within a matter of a few days, its position had changed; 

arbitrarily and capriciously disallowed the calculation of any amounts awarded under Rule 68 arising 

from the Offer of Judgment as a "penalty" despite the fact that it knew or should have known that no 

authority whatsoever existed for this position, including any state or federal published appellate 

decision. 

45. Upon information and belief, when making the decision to disallow attorneys' fees, defense 

costs, and damages related to the Offer of Judgment, Defendants did so with a direct intent to injure 

Plaintiffs and maximize profits. 

46. Upon information and belief, Defendants conducted an audit of Plaintiffs records, and knew or 

should have known that in addition to the amounts claimed by the Plaintiff, Plaintiffs should be entitled 

to an offset for indemnity payments made by Way of a write-off of medical expenses in favor of 

Plaintiffs Orosco in the amount of $307,630.38, and yet knowingly failed to include that amount as an 

offset or notify its insured of the oversight. 

47. As a direct and proximate result of the Defendants' collective breach of the duty of good faith 

and fair dealing, Plaintiffs have been damaged in an amount to be proven at trial. 

COUNT III 

(Bad Faith) 

48. Plaintiff incorporates by reference each and every preceding allegation as though fully set forth 

herein. 

49.- At all material times, Defendant Lexington (and Defendant AIG acting as its Agent in the 

administration of claims) owed a duty to exercise good faith and fair dealing toward their insured. 

50. At all material times, Plaintiffs relied upon the nature of this good faith and special relationship 

in providing complete access to the litigation file, and reasonably relied upon Defendants to provide 

notice with respect to any reservation regarding coverage. 

51. Defendants breached the duty of good faith and fair dealing when they engaged in cumulative 

acts of bad faith including, but not limited to: conducting an audit and yet withholding any notification 

-7- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

capricious fashion (demonstrated by the fact that within a matter of a few days, its position had changed; 

arbitrarily and capriciously disallowed the calculation of any amounts awarded under Rule 68 arising 

from the Offer of Judgment as a "penalty" despite the fact that it knew or should have known that no 

authority whatsoever existed for this position, including any state or federal published appellate 

decision. 

45. Upon information and belief, when making the decision to disallow attorneys' fees, defense 

costs, and damages related to the Offer of Judgment, Defendants did so with a direct intent to injure 

Plaintiffs and maximize profits. 

46. Upon information and belief, Defendants conducted an audit of Plaintiffs records, and knew or 

should have known that in addition to the amounts claimed by the Plaintiff, Plaintiffs should be entitled 

to an offset for indemnity payments made by Way of a write-off of medical expenses in favor of 

Plaintiffs Orosco in the amount of $307,630.38, and yet knowingly failed to include that amount as an 

offset or notify its insured of the oversight. 

47. As a direct and proximate result of the Defendants' collective breach of the duty of good faith 

and fair dealing, Plaintiffs have been damaged in an amount to be proven at trial. 

COUNT III 

(Bad Faith) 

48. Plaintiff incorporates by reference each and every preceding allegation as though fully set forth 

herein. 

49.- At all material times, Defendant Lexington (and Defendant AIG acting as its Agent in the 

administration of claims) owed a duty to exercise good faith and fair dealing toward their insured. 

50. At all material times, Plaintiffs relied upon the nature of this good faith and special relationship 

in providing complete access to the litigation file, and reasonably relied upon Defendants to provide 

notice with respect to any reservation regarding coverage. 

51. Defendants breached the duty of good faith and fair dealing when they engaged in cumulative 

acts of bad faith including, but not limited to: conducting an audit and yet withholding any notification 

-7- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 8 of 33
regarding reservations; conducting an audit and yet refusing to acknowledge a credit against the SIR 

with regard to a "write-off' of medical expenses representing an indemnity payment to Orosco; 

requesting updates, reporting and access to otherwise privileged information which it then relied upon to 

disclaim coverage without a reasonable factual basis; denying coverage for amounts awarded to Plaintiff 

pursuant to Rule 68 despite the fact that no appellate level decision has ever allowed a carrier to do so; 

conducting an internal audit of attorneys' fees and expenses incurred and taking an "across the board" 

deduction with regard to such expenses without reasonable support despite the fact that there was no 

definition or guideline regarding such fees; and further conduct as will be demonstrated at the time of 

trial. The aforementioned actions demonstrate an evil hand guided by an evil mind warranting the 

imposition of punitive damages. 

52. As a direct and proximate result of the Defendants breach of the duty of good faith and fair 

dealing and cumulative acts of bad faith, Plaintiff sustained damage in an amount to be proven at trial. 

COUNT IV 

(Declaratory Relief) 

53. Plaintiffs incorporate by reference each and every preceding allegation as though fully set forth 

herein. 

54. Lexington issued an Excess Healthcare Professional Liability policy bearing Policy No. 

6793282, which Policy was designed to protect the District as an insured for any covered loss in excess 

of the self-insured retention of $5 million after appropriate offset for erosion due to indemnity and 

expense. 

55. The Policy does not define the "expenses and indemnity" which are said to "erode" the SIR. 

56. Lexington authored the Policy, and as such was required to avoid any ambiguity; Arizona law 

dictates that any ambiguity will be construed against the Insurer and in favor of the Insured, particularly 

where that term appears in an exclusion that purports to limit or exclude coverage. 

57. Plaintiff incurred expenses in the defense of the Orosco litigation, which expenses Defendants 

were aware of for years following multiple audits and reports and yet expressed no reservation of rights 

-s1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

regarding reservations; conducting an audit and yet refusing to acknowledge a credit against the SIR 

with regard to a "write-off' of medical expenses representing an indemnity payment to Orosco; 

requesting updates, reporting and access to otherwise privileged information which it then relied upon to 

disclaim coverage without a reasonable factual basis; denying coverage for amounts awarded to Plaintiff 

pursuant to Rule 68 despite the fact that no appellate level decision has ever allowed a carrier to do so; 

conducting an internal audit of attorneys' fees and expenses incurred and taking an "across the board" 

deduction with regard to such expenses without reasonable support despite the fact that there was no 

definition or guideline regarding such fees; and further conduct as will be demonstrated at the time of 

trial. The aforementioned actions demonstrate an evil hand guided by an evil mind warranting the 

imposition of punitive damages. 

52. As a direct and proximate result of the Defendants breach of the duty of good faith and fair 

dealing and cumulative acts of bad faith, Plaintiff sustained damage in an amount to be proven at trial. 

COUNT IV 

(Declaratory Relief) 

53. Plaintiffs incorporate by reference each and every preceding allegation as though fully set forth 

herein. 

54. Lexington issued an Excess Healthcare Professional Liability policy bearing Policy No. 

6793282, which Policy was designed to protect the District as an insured for any covered loss in excess 

of the self-insured retention of $5 million after appropriate offset for erosion due to indemnity and 

expense. 

55. The Policy does not define the "expenses and indemnity" which are said to "erode" the SIR. 

56. Lexington authored the Policy, and as such was required to avoid any ambiguity; Arizona law 

dictates that any ambiguity will be construed against the Insurer and in favor of the Insured, particularly 

where that term appears in an exclusion that purports to limit or exclude coverage. 

57. Plaintiff incurred expenses in the defense of the Orosco litigation, which expenses Defendants 

were aware of for years following multiple audits and reports and yet expressed no reservation of rights 

-s1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 9 of 33
or concern until two years after Judgment was entered. 

58. Plaintiff incurred an indemnity expense when it gave a complete credit to the Plaintiff in the 

amount of $307,630.38 with regard to medical expenses incurred by (and which would have been paid 

directly to) Plaintiff, however the District agreed to "write-off' those medical bills in order to reduce the 

indemnity exposure to Orosco in the way of "special damages". This "write-off" directly reduced the 

amount of damages recoverable by Orosco, and thus inured directly to the benefit of Defendant 

Lexington. 

59. Although the original language of the Policy purported to exclude coverage for: 

"Any fines, penalties, punitive, exemplary, multiply damages or the 

multiple portion of multiple damages" 

the Policy was amended by way of amendatory Endorsement No. 9 to provide instead only an exclusion 

with regard to "any fines or penalties." 

60. The Policy was specifically endorsed, therefore to include any damages that would be fairly 

characterized as punitive, exemplary, multiplied damages or the multiple portion of multiple damages. 

61. An ambiguity will be said to exist where a term is capable of more than one interpretation. 

62. Defendants denied coverage for the award made to Plaintiffs Orosco pursuant to Rule 68 arguing 

that a sanction under Rule 68 (for a wholly innocent failure to have accepted an Offer of Judgment 

without any showing of nefarious conduct, ill will, or wrongful misconduct) was tantamount to a penalty • 

within the meaning of the Policy despite the fact that the Policy contains no definition of "penalties". 

63. The Policy does not exclude coverage for "sanctions." 

64. Multiple courts in multiple jurisdictions have declined to enforce a "penalty" exclusion where 

the enforcement of that provision would be contrary to the reasonable expectations of the insured. Many 

courts have declined to enforce a "penalty" exclusion because it is susceptible to more than one meaning 

or definition, and many courts interpret "penalty" to represent a fine or levy imposed by a governmental 

entity or authority rather than an award made in a civil proceeding to the opposing party. 

65. Rule 68 does not utilize the term "penalty" but rather refers to the awards made pursuant to Rule 

-9- 

1 

2 

3 

4 

/5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

or concern until two years after Judgment was entered. 

58. Plaintiff incurred an indemnity expense when it gave a complete credit to the Plaintiff in the 

amount of $307,630.38 with regard to medical expenses incurred by (and which would have been paid 

directly to) Plaintiff, however the District agreed to "write-off' those medical bills in order to reduce the 

indemnity exposure to Orosco in the way of "special damages". This "write-off" directly reduced the 

amount of damages recoverable by Orosco, and thus inured directly to the benefit of Defendant 

Lexington. 

59. Although the original language of the Policy purported to exclude coverage for: 

"Any fines, penalties, punitive, exemplary, multiply damages or the 

multiple portion of multiple damages" 

the Policy was amended by way of amendatory Endorsement No. 9 to provide instead only an exclusion 

with regard to "any fines or penalties." 

60. The Policy was specifically endorsed, therefore to include any damages that would be fairly 

characterized as punitive, exemplary, multiplied damages or the multiple portion of multiple damages. 

61. An ambiguity will be said to exist where a term is capable of more than one interpretation. 

62. Defendants denied coverage for the award made to Plaintiffs Orosco pursuant to Rule 68 arguing 

that a sanction under Rule 68 (for a wholly innocent failure to have accepted an Offer of Judgment 

without any showing of nefarious conduct, ill will, or wrongful misconduct) was tantamount to a penalty • 

within the meaning of the Policy despite the fact that the Policy contains no definition of "penalties". 

63. The Policy does not exclude coverage for "sanctions." 

64. Multiple courts in multiple jurisdictions have declined to enforce a "penalty" exclusion where 

the enforcement of that provision would be contrary to the reasonable expectations of the insured. Many 

courts have declined to enforce a "penalty" exclusion because it is susceptible to more than one meaning 

or definition, and many courts interpret "penalty" to represent a fine or levy imposed by a governmental 

entity or authority rather than an award made in a civil proceeding to the opposing party. 

65. Rule 68 does not utilize the term "penalty" but rather refers to the awards made pursuant to Rule 

-9- 

1 

2 

3 

4 

/5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 10 of 33
68 as representing a sanction; Defendants took the position that a "sanction" can be a penalty (under one 

possible definition) where the penalty is imposed for a "violation of law, rule or order of court". 

66. At no time did Plaintiffs violate any law, rule, or order of court. 

67. Despite the fact that Defendant Lexington did not define the terms "expense" "indemnity" or 

"penalty" anywhere within its Policy, and despite the fact that the term "penalty" is susceptible to many 

definitions, none of which apply in the present setting, Defendant has wrongfully_ failed and refused to 

afford coverage and/or allow a credit against the SIR for erosion due to expense, indemnity, and awards 

made pursuant to Rule 68 resulting from Plaintiffs failure to accept the Offer of Judgment during the 

course of litigation. 

68. An "actual controversy" exists within the meaning of A.R.S. § 12-1821 et. seq. between Plaintiff 

and Defendants regarding coverage available under the Policy. 

69. Plaintiff respectfully requests a judicial declaration finding as follows: 

1. That the term "penalty" is susceptible to more than one definition, and as such is an 

ambiguous term that will be construed against Lexington and in favor of Plaintiff; 

2. That a party's innocent failure to forecast its potential exposure, and resultant failure to accept 

an Offer of Judgment resulting in an award of damages under Rule 68 does not amount to a "penalty" 

within the meaning of a "penalty" exclusion as set forth within the Lexington Policy; 

3. That having issued no guidelines for legal billing and setting forth no definition with regard to 

the term "expense" that would erode the SIR, Lexington may not dispute those expenses of which it was 

aware and had audited for years prior to denying coverage; 

4. That the agreement of Plaintiffs to "write off' and provide a credit with regard to medical 

expenses that would have been owed by Brandon Orosco represent an "indemnity" expense, which term 

is not defined within the Lexington Policy, and accordingly Plaintiff is entitled to erosion of the SIR in 

the corresponding sum of $307,630.38. 

Plaintiffs further request an award of attorneys' fees incurred herein pursuant to A.R.S. § 12-

341.01 as this matter arises out of contract. 

-10- 

68 as representing a sanction; Defendants took the position that a "sanction" can be a penalty (under one 

possible definition) where the penalty is imposed for a "violation of law, rule or order of court". 

66. At no time did Plaintiffs violate any law, rule, or order of court. 

67. Despite the fact that Defendant Lexington did not define the terms "expense" "indemnity" or 

"penalty" anywhere within its Policy, and despite the fact that the term "penalty" is susceptible to many 

definitions, none of which apply in the present setting, Defendant has wrongfully_ failed and refused to 

afford coverage and/or allow a credit against the SIR for erosion due to expense, indemnity, and awards 

made pursuant to Rule 68 resulting from Plaintiffs failure to accept the Offer of Judgment during the 

course of litigation. 

68. An "actual controversy" exists within the meaning of A.R.S. § 12-1821 et. seq. between Plaintiff 

and Defendants regarding coverage available under the Policy. 

69. Plaintiff respectfully requests a judicial declaration finding as follows: 

1. That the term "penalty" is susceptible to more than one definition, and as such is an 

ambiguous term that will be construed against Lexington and in favor of Plaintiff; 

2. That a party's innocent failure to forecast its potential exposure, and resultant failure to accept 

an Offer of Judgment resulting in an award of damages under Rule 68 does not amount to a "penalty" 

within the meaning of a "penalty" exclusion as set forth within the Lexington Policy; 

3. That having issued no guidelines for legal billing and setting forth no definition with regard to 

the term "expense" that would erode the SIR, Lexington may not dispute those expenses of which it was 

aware and had audited for years prior to denying coverage; 

4. That the agreement of Plaintiffs to "write off' and provide a credit with regard to medical 

expenses that would have been owed by Brandon Orosco represent an "indemnity" expense, which term 

is not defined within the Lexington Policy, and accordingly Plaintiff is entitled to erosion of the SIR in 

the corresponding sum of $307,630.38. 

Plaintiffs further request an award of attorneys' fees incurred herein pursuant to A.R.S. § 12-

341.01 as this matter arises out of contract. 

-10- 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 11 of 33
PRAYER FOR RELIEF 

WHEREFOR, having fully stated its claim against the Defendants, Plaintiff prays for judgment 

as follows: 

1. Declaratory relief consistent with the request made herein in association with Count IV; 

2. For compensatory damages reflecting any and all amounts wrongfully denied by 

Lexington; 

3. For punitive damages associated with the claim of bad faith; 

4. For attorneys' fees and defense costs with regard to those actions based in contract 

pursuant to A.R.S. § 12-341.01; and 

5. For a trial by jury and such other and further relief as the court deems just and proper 

under the circumstances. 

RESPECTFULLY submitted this 15th day of September, 2017. 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

Sha urphy o 

The Gibraltar Buildi 

6611 North Scottsd. - •oad 

Scottsdale, Arizona 85250 

Attorneys for Maricopa County Special Health Care District 

aka Maricopa Integrated Health System 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

-11- 

PRAYER FOR RELIEF 

WHEREFOR, having fully stated its claim against the Defendants, Plaintiff prays for judgment 

as follows: 

1. Declaratory relief consistent with the request made herein in association with Count IV; 

2. For compensatory damages reflecting any and all amounts wrongfully denied by 

Lexington; 

3. For punitive damages associated with the claim of bad faith; 

4. For attorneys' fees and defense costs with regard to those actions based in contract 

pursuant to A.R.S. § 12-341.01; and 

5. For a trial by jury and such other and further relief as the court deems just and proper 

under the circumstances. 

RESPECTFULLY submitted this 15th day of September, 2017. 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

Sha urphy o 

The Gibraltar Buildi 

6611 North Scottsd. - •oad 

Scottsdale, Arizona 85250 

Attorneys for Maricopa County Special Health Care District 

aka Maricopa Integrated Health System 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

-11- 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 12 of 33
EXHIBIT “B”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 13 of 33
ORIGINAL 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com Attorneys for Maricopa County Special Health Care District 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTRY SPECIAL No. CV2017-054614 

HEALTH CARE DISTRICT, a body 

politic,, governing body for and doing 

business as MARICOPA 

INTEGRATED HEALTH SYSTEM, 

Plaintiff, 

SUMMONS TO AIG CLAIMS, INC. 

v. 

LEXINGTON INSURANCE 

COMPANY, a foreign capital stock 

insurance company, and AIG CLAIMS, 

INC., a foreign corporation, ABC If you would like legal advice from a lawyer, 

PARTNERSHIPS, JOHN DOES I-V, 

CORPORATIONS, XYZ Contact the Lawyer Referral Service at 

602-257-4434 

Of 

and JANE DOES I-V, Www,maricooalawiers.org 

Sponsored by the 

Defendants. Maricopa County Bar Association 

THE STATE OF ARIZONA TO THE DEFENDANT: 

SIG Claims, Inc„, 

The Prentice-Hall Corporation 

2338 W. Royal Palm Road 

Suite J 

Phoenix, Arizona 85021 

YOU ARE HEREBY SUMMONED and required to appear and defend, within the time 

applicable, in this action in this Court. If served within Arizona, you shall appear and defend within 20 

1 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

ORIGINAL 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com Attorneys for Maricopa County Special Health Care District 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTRY SPECIAL No. CV2017-054614 

HEALTH CARE DISTRICT, a body 

politic,, governing body for and doing 

business as MARICOPA 

INTEGRATED HEALTH SYSTEM, 

Plaintiff, 

SUMMONS TO AIG CLAIMS, INC. 

v. 

LEXINGTON INSURANCE 

COMPANY, a foreign capital stock 

insurance company, and AIG CLAIMS, 

INC., a foreign corporation, ABC If you would like legal advice from a lawyer, 

PARTNERSHIPS, JOHN DOES I-V, 

CORPORATIONS, XYZ Contact the Lawyer Referral Service at 

602-257-4434 

Of 

and JANE DOES I-V, yvww,maricoOalawiers.org 

Sponsored by the 

Defendants. Maricopa County Bar Association 

THE STATE OF ARIZONA TO THE DEFENDANT: 

SIG Claims, Inca 

The Prentice-Hall Corporation 

2338 W. Royal Palm Road 

Suite J 

Phoenix, Arizona 85021 

YOU ARE HEREBY SUMMONED and required to appear and defend, within the time 

applicable, in this action in this Court. If served within Arizona, you shall appear and defend within 20 

1 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

1 

2 

~ 

~ 

4 

5 

6 

7 

8 

9 

10 

ORIGINAL 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com 

Attorneys for Maricopa County Special Health Care District 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTRY SPECIAL ) No. CV2017-054614 

HEALTH CARE DISTRICT, a body ) 

politic,, governing body for and doing ) 

business as MARICOPA ) 

INTEGRATED HEALTH SYSTEM, ) 

Plaintiff, 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

I V. 

LEXINGTON INSURANCE 

COMPANY, a foreign capital stock 

insurance company, and AIG CLAIMS, 

INC., a foreign corporation, ABC 

CORPORATIONS, XYZ 

PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

Defendants. 

SUMMONS TO AIG CLAIMS, INC. 

If you would like lesal advice from a lawyer, 

Contact the Lawyer Referral Service at 

602-257-4434 

or 

Aww.marico alawvers.ore 

Sponsored by the 

Maricopa County 8ar fassociation 

THE STATE OF ARIZONA TO THE DEFENDANT: 

^~IG_Claims, Ins.~► 

The Prentice-Hall Corporation 

2338 W. Royal Palm Road 

Suite J 

Phoenix, Arizona 85021 

YOU ARE HEREBY SUMMONED and required to appear and defend, within the time 

applicable, in this action in this Court. If served within Arizona, you shall appear and defend witllin 20 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 14 of 33
days after the service of the Summons and Complaint upon you, exclusive of the day of service. If 

served out of the State of Arizona - whether by direct service, by registered or certified mail, or by 

publication - you shall appear and defend within 30 days after the service of the Summons and 

Complaint upon you is complete, exclusive of the day of service. Where process is served upon the 

Arizona Director of Insurance as an insurer's attorney to receive service of legal process against it in this 

state, the insurer shall not be required to appear, answer or plead until expiration of 40 days after date of 

such service upon the Director. Service by registered or certified mail without the State of Arizona is 

complete 30 days after the date of filing the receipt and affidavit of service with the Court. Service by 

publication is complete 30 days after the date of first publication. Direct service is complete when 

made. Service upon the Arizona Motor Vehicle Superintendent is complete 30 days after filing the 

Affidavit of Compliance and return receipt or Officer's Return. Requests for reasonable accommodation 

for persons with disabilities must be made to the court by parties at least 3 working days in advance of a 

scheduled court proceeding. Ariz. R. Civ. P. 4; ARS Sections 20-222, 28-502, 28-503. 

YOU ARE HEREBY NOTIFIED that in case of your failure to appear and defend within the 

time applicable, judgment by default may be rendered against you for the relief demanded in the 

Complaint. 

YOU ARE CAUTIONED that in order to appear and defend, you must file an Answer or proper 

response in writing with the Clerk of this Court, accompanied by the necessary filing fee, within the 

time required, and you are required to serve a copy of any Answer or response upon the Plaintiffs 

attorney. Ariz. R. Civ. P. 5, 10(d); ARS Section 12-311. 

The name and address of Plaintiff's attorney is: 

Shawna Murphy Woner 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

-2- 

1 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

days after the service of the Summons and Complaint upon you, exclusive of the day of service. If 

served out of the State of Arizona - whether by direct service, by registered or certified mail, or by 

publication - you shall appear and defend within 30 days after the service of the Summons and 

Complaint upon you is complete, exclusive of the day of service. Where process is served upon the 

Arizona Director of Insurance as an insurer's attorney to receive service of legal process against it in this 

state, the insurer shall not be required to appear, answer or plead until expiration of 40 days after date of 

such service upon the Director. Service by registered or certified mail without the State of Arizona is 

complete 30 days after the date of filing the receipt and affidavit of service with the Court. Service by 

publication is complete 30 days after the date of first publication. Direct service is complete when 

made. Service upon the Arizona Motor Vehicle Superintendent is complete 30 days after filing the 

Affidavit of Compliance and return receipt or Officer's Return. Requests for reasonable accommodation 

for persons with disabilities must be made to the court by parties at least 3 working days in advance of a 

scheduled court proceeding. Ariz. R. Civ. P. 4; ARS Sections 20-222, 28-502, 28-503. 

YOU ARE HEREBY NOTIFIED that in case of your failure to appear and defend within the 

time applicable, judgment by default may be rendered against you for the relief demanded in the 

Complaint. 

YOU ARE CAUTIONED that in order to appear and defend, you must file an Answer or proper 

response in writing with the Clerk of this Court, accompanied by the necessary filing fee, within the 

time required, and you are required to serve a copy of any Answer or response upon the Plaintiffs 

attorney. Ariz. R. Civ. P. 5, 10(d); ARS Section 12-311. 

The name and address of Plaintiff's attorney is: 

Shawna Murphy Woner 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

-2- 

1 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

days after the service of the Summons and Complaint upon you, exclusive of the day of service. If 

served out of the State of Arizona - whether by direct service, by registered or certified mail, or by 

publication - you shall appear and defend within 30 days after the service of the Summons and 

Complaint upon you is complete, exclusive of the day of service. Where process is served upon the 

Arizona Director of Insurance as an insurer's attorney to receive service of legal process against it in this 

state, the insurer shall not be required to appear, answer or plead until expiration of 40 days after date of 

such service upon the Director. Service by registered or certified mail without the State of Arizona is 

complete 30 days after the date of filing the receipt and affidavit of service with the Court. Service by 

publication is complete 30 days after the date of first publication. Direct service is complete when 

made. Service upon the Arizona Motor Vehicle Superintendent is complete 30 days after filing the 

Affidavit of Compliance and return receipt or Officer's Return. Requests for reasonable accommodation 

for persons with disabilities must be made to the court by parties at least 3 working days in advance of a 

scheduled court proceeding. Ariz. R. Civ. P. 4; ARS Sections 20-222, 28-502, 28-503. 

YOU ARE HEREBY NOTIFIED that in case of your failure to appear and defend within the 

time applicable, judgment by default may be rendered against you for the relief demanded in the 

Complaint. 

YOU ARE CAUTIONED that in order to appear and defend, you must file an Answer or proper 

response in writing with the Clerk of this Court, accompanied by the necessary filing fee, within the 

time required, and you are required to serve a copy of any Answer or response upon the Plaintiff s 

attorney. Ariz. R. Civ. P. 5, 10(d); ARS Section 12-311. 

The name and address of Plaintiff s attorney is: 

Shawna Murphy Woner 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar' Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

-2- 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 15 of 33
ja 

NOV -72017 

SIGNED AND SEALED this date: 

1 

2 

3 

4 

5 

6 Clerk IMMIIAEL SC AO Mg. CLERK 

7 

8 

9 

10 

11 

A. McLoone 

Deputy CIerk. 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

-3- 

NOV - 7 2017 

SIGNED AND SEALED this date: 

Clerk gvellAEL SC AO Mg. CLERK 

A. McLoone 

Deputy Clerk. 

-3- 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

NpU - 7 2017 

SIGNED AND SEALED this date: 

Clerk ~~~~~9I_ fC .3~AR~S. ~~F!~ 

A. McL®oyv 

DePuty:~qf,, -~ 

-3- 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 16 of 33
EXHIBIT “C”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 17 of 33
cry. 

csc 

Cll 

csc 

Notice of Service of Process

null / ALL

Transmittal Number: 17377143

Date Processed: 11/09/2017

Primary Contact: Eric Manne

AIG Property Casualty

80 Pine St

Fl 13

New York, NY 10005-1734

Entity: AIG Claims, Inc.

Entity ID Number 0016692

Entity Served: AIG Claims, Inc.

Title of Action: Maricopa Country Special Health Care District, a body politic, governing body for

and doing business as Maricopa Integrated Health System vs. Lexington

Insurance Company

Document(s) Type: Summons/Complaint

Nature of Action: Contract

Court/Agency: Maricopa County Superior Court, Arizona

Case/Reference No: CV2017-054614

Jurisdiction Served: Arizona

Date Served on CSC: 11/08/2017

Answer or Appearance Due: 20 Days

Originally Served On: CSC

How Served: Personal Service

Sender Information: Shawna Murphy Woner

480-483-9700

Information contained on this transmittal form is for record keeping, notification and forwarding the attached document(s). It does not

constitute a legal opinion. The recipient is responsible for interpreting the documents and taking appropriate action.

To avoid potential delay, please do not send your response to CSC

251 Little Falls Drive, Wilmington, Delaware 19808-1674 (888) 690-2882 | sop@cscglobal.com

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 18 of 33
EXHIBIT “D”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 19 of 33
A

I 

0 

L 

1 

e 

S 

1 

1 

/ 

4 

2 

0 

1 

7 

No. CV2017-054614 RECEIVED 

LEGAL DEPARTMENT 

SUMMONS TO LEXINGTON INSURANCE 

COMPANY 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner(@sphplaw.com 

Attorneys for Maricopa County Special Health Care District 

4100 0 

A riroe 

COPretirmsr A YLFs, 

Pilocess 

eAssefit frefi 

AND 

0/8/NtEile-srEb 

PoN 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTRY SPECIAL ) 

HEALTH CARE DISTRICT, a body ) 

politic, governing body for and doing ) 

business as MARICOPA ) 

INTEGRATED HEALTH SYSTEM, ) 

) 

Plaintiff, ) 

) 

v. ) 

) 

LEXINGTON INSURANCE ) 

COMPANY, a foreign capital stock ) 

insurance company, and AIG CLAIMS, ) 

INC., a foreign corporation, ABC ) 

CORPORATIbNS, XYZ ) 

PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

) 

) 

) 

Defendants. 

THE STATE OF ARIZONA TO THE DEFENDANT: 

Lexington Insurance Company. 

Counsel, Legal Department, Lexington Insurance Company 

100 Summer Street 

Boston, Massachusetts 02110-2103 

YOU ARE HEREBY SUMMONED and required to appear and defend, within the time 

applicable, in this action in this Court. If served within Arizona, you shall appear and defend within 20 

days after the service of the Summons and Complaint upon you, exclusive of the day of service. If 

I 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

A

I 

0 

L 

1 

e 

S 

1 

1 

/ 

4 

2 

0 

1 

7 

No. CV2017-054614 RECEIVED 

LEGAL DEPARTMENT 

SUMMONS TO LEXINGTON INSURANCE 

COMPANY 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner(@sphplaw.com 

Attorneys for Maricopa County Special Health Care District 

4100 0 

A riroe 

COPretirmsr A YLFs, 

Pilocess 

eAssefit frefi 

AND 

0/8/NtEile-srEb 

PoN 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTRY SPECIAL ) 

HEALTH CARE DISTRICT, a body ) 

politic, governing body for and doing ) 

business as MARICOPA ) 

INTEGRATED HEALTH SYSTEM, ) 

) 

Plaintiff, ) 

) 

v. ) 

) 

LEXINGTON INSURANCE ) 

COMPANY, a foreign capital stock ) 

insurance company, and AIG CLAIMS, ) 

INC., a foreign corporation, ABC ) 

CORPORATIbNS, XYZ ) 

PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

) 

) 

) 

Defendants. 

THE STATE OF ARIZONA TO THE DEFENDANT: 

Lexington Insurance Company. 

Counsel, Legal Department, Lexington Insurance Company 

100 Summer Street 

Boston, Massachusetts 02110-2103 

YOU ARE HEREBY SUMMONED and required to appear and defend, within the time 

applicable, in this action in this Court. If served within Arizona, you shall appear and defend within 20 

days after the service of the Summons and Complaint upon you, exclusive of the day of service. If 

I 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

y1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scpttsdale Road 

Scottsdaie, Arizona 85250 

(480)483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com 

Attorneys foFMaricopa County Special Health Care District 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTRY SPECIAL 

HEALTH CAi^ DISTRICT, a body 

politic, governing body for and doing 

business as MARICOPA 

INTEGRATED HEALTH SYSTEM. 

Plaintiff, 

V. 

LEXINGTON. INSURANCE 

COMPANY, a foreign capital stock 

insurance conipany, and AIG CLAIMS, 

INC., a foreign corporation, ABC 

CORPORATlbNS, XYZ 

PARTNERSHjlPS, JOHN DOES I-V, 

and JANE DOES I-V, 

Defendants. 

No. CV2017-054614 

Kwv 13 ^Of7 

LEGAL DEPARTMENT 

SUMMONS TO LEXINGTON INSURANCE 

COMPANY 

THE STATE OF ARIZONA TO THE DEFENDANT: 

Lexington Insurance Company 

( Counsel, Legal Department, Lexington Insurance Company 

100 Summer Street 

I Boston, Massachusetts 02110-2103 

YOU HEREBY SUMMONED and required to appear and defend, within the time 

applicable, in this action in this Court. If served within Arizona, you shall appear and defend within 20 

days after the service of the Summons and Complaint upon you, exclusive of the day of service. If 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 20 of 33
A 

G 

I 

0 

L 

1 

e 

S 

1 

1 

1 

4 

2 

0 

1 

7 

served out of the State of Arizona - whether by direct service, by registered or certified mail, or by 

publication - you shall appear and defend within 30 days after the service of the Summons and 

Complaint upon you is complete, exclusive of the day of service. Where process is served upon the 

Arizona Director of Insurance as an insurer's attorney to receive service of legal process against it in this 

state, the insurer shall not be required to appear, answer or plead until expiration of 40 days after date of 

such service upon the Director. Service by registered or certified mail without the State of Arizona is 

complete 30 days after the date of filing the receipt and affidavit of service with the Court. Service by 

publication is complete 30 days after the date of first publication. Direct service is complete when 

made. Service (upon the Arizona Motor Vehicle Superintendent is complete 30 days after filing the 

Affidavit of Compliance and return receipt or Officer's Return. Requests for reasonable accommodation 

for persons with, disabilities must be made to the court by parties at least 3 working days in advance of a 

scheduled court proceeding. Ariz. R. Civ. P. 4; ARS Sections 20-222, 28-502, 28-503. 

YOU ARE HEREBY NOTIFIED that in case of your failure to appear and defend within the 

time applicable, judgment by default may be rendered against you for the relief demanded in the 

Complaint. 

YOU ARE CAUTIONED that in order to appear and defend, you must file an Answer or proper 

response in writing with the Clerk of this Court, accompanied by the necessary filing fee, within the 

time required, and you are required to serve a copy of any Answer or response upon the Plaintiffs 

attorney. Ariz. R. Civ. P. 5, 10(d); ARS Section 12-311. 

The name and address of Plaintiffs attorney is: 

Shawna Murphy Woner 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Spottsdale, Arizona 85250 

(480) 483-9700 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

A 

G 

I 

0 

L 

1 

e 

S 

1 

1 

1 

4 

2 

0 

1 

7 

served out of the State of Arizona - whether by direct service, by registered or certified mail, or by 

publication - you shall appear and defend within 30 days after the service of the Summons and 

Complaint upon you is complete, exclusive of the day of service. Where process is served upon the 

Arizona Director of Insurance as an insurer's attorney to receive service of legal process against it in this 

state, the insurer shall not be required to appear, answer or plead until expiration of 40 days after date of 

such service upon the Director. Service by registered or certified mail without the State of Arizona is 

complete 30 days after the date of filing the receipt and affidavit of service with the Court. Service by 

publication is complete 30 days after the date of first publication. Direct service is complete when 

made. Service (upon the Arizona Motor Vehicle Superintendent is complete 30 days after filing the 

Affidavit of Compliance and return receipt or Officer's Return. Requests for reasonable accommodation 

for persons with, disabilities must be made to the court by parties at least 3 working days in advance of a 

scheduled court proceeding. Ariz. R. Civ. P. 4; ARS Sections 20-222, 28-502, 28-503. 

YOU ARE HEREBY NOTIFIED that in case of your failure to appear and defend within the 

time applicable, judgment by default may be rendered against you for the relief demanded in the 

Complaint. 

YOU ARE CAUTIONED that in order to appear and defend, you must file an Answer or proper 

response in writing with the Clerk of this Court, accompanied by the necessary filing fee, within the 

time required, and you are required to serve a copy of any Answer or response upon the Plaintiffs 

attorney. Ariz. R. Civ. P. 5, 10(d); ARS Section 12-311. 

The name and address of Plaintiffs attorney is: 

Shawna Murphy Woner 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Spottsdale, Arizona 85250 

(480) 483-9700 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

served out of the State of Arizona - whether by direct service, by registered or certified mail, or by 

publication - you shall appear and defend within 30 days after the service of the Summons and 

Complaint upon you is complete, exclusive of the day of service. Where process is served upon the 

y 

Arizona Director of Insurance as an insurer's attorney to receive service of legal process against it in this 

state, the insurer shall not be required to appear, answer or plead until expiration of 40 days after date of 

such service upon the Director. Service by registered or certified mail without the State of Arizona is 

complete 30 days after the date of filing the receipt and affidavit of service with the Court. Service by 

publication is complete 30 days after the date of first publication. Direct service is complete when 

made. Service .upon the Arizona Motor Vehicle Superintendent is complete 30 days after filing the 

Affidavit of Coippliance and return receipt or Officer's Return. Requests for reasonable accommodation 

5' 

for persons with, disabilities must be made to the court by parties at least 3 working days in advance of a 

scheduled court ^proceeding. Ariz. R. Civ, P. 4; ARS Sections 20-222, 28-502, 28-503. 

( 

YOU AM HEREBY NOTIFIED that in case of your failure to appear and defend within the 

time applicable,^ judgment by default may be rendered against you for the relief demanded in the 

Complaint. 

YOU ARE CAUTIONED that in order to appear and defend, you must file an Answer or proper 

response in writing with the Clerk of this Court, accompanied by the necessary filing fee, within the 

time required, and you are required to serve a copy of any Answer or response upon the Plaintiffs 

attorney. Ariz. R. Civ. P. 5, 10(d); ARS Section 12-311. * 

y 

The name and address of Plaintiff s attomey is: 

Shawna Murphy Woner 

CrARREY, WONER, HOFFMASTER & PESHEK, P.C. 

Ijhe Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

-2-

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 21 of 33
SIGNED AND SEALED this date: 

- 20w 

M4el4AK. Jf.A1485, etERK 

Clerk 

1 

2 

.3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

-3- 

SIGNED AND SEALED this date: 

figeHAEL Jaws, OtERK 

0 

L 

1 

e 

S 

1 

1 

1 

4 

2 

0 

1 

7 

A

I 

1 

2 

.3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

1 

2 

.3 

4 

. 5 

6 

7 

8 

9 

10 

n 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

SIGNED AND SEALED this date: 

-3-

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 22 of 33
EXHIBIT “E”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 23 of 33
(Richard F. Acres) 

Attorney& Party olhoot Money 

Shawna Woner 

Garrey Woner Hoff:nester' 8 Peshek PC 

6611 North Scottsdale Road 

Scottsdale, AZ 85250 

'CLEM-101'B Ma: (480) 483-9700 

/Wormy Am 

I 4 

:t. 

.1 , * LOP -I tt I 01.pe 1 

aiiNOV

t• hilf ( 

. 13 A R, 

fin 9:08 

FILED BY C. CARABA JAL, 

Re NV orfle No.: 

- 5-581 

Insert nOme of Court and Juckial Ugric, and Branch Court: 

In MARICOPA COUNTY SUPERIOR COURT in and for the County of MARICOPA 

Peffocer Maricopa Country Special Health Care District, a body politic, governing body for and doing 

business as Maricopa Intergrated Health System, 

Respondent Lexington Insurance Company, a foreign capital stock Insurance company, and AIG Claims, 

Inc., a foreign corporation, et al., 

CERTIFICATE OF SERVICE 

HEARING DATE: TlAIE: DEPT.: CASE NUMBER: 

CV2017-054614 

I declare under penalty of perjury under the laws of the State of Arizona that the foregoing Is true and correct. At the time of 

service I was at least 18 years of age and authorized to serve process in this case. 

I served copies of the 2 Sets - Summons to Lexington Insurance Company.; Complaint; Certificate Regarding Compulsory 

Arbitration; Demand for Jury Trial; Request For Production of Documents to All Defendants; Request For Admissions to MG 

Claims, Inc.; Non-Uniform Interrogatories to Defendant AIG Claims, Inc.; Acceptance Fee Check #16977 - $15.00 

a. Party served Lexington Insurance Company do Arizona Department of Insurance 

b. Person Served Elizabeth Villalino - Administrative Assistant III 

Age: 23 yrs. Race: Hispanic Sex: Female Eyes: Brown Height: 5'6 - 6'0 Weight: 130 lbs. Hair: Black 

Address where served: 2910 N 44th St Ste 210 

Phoenix, AZ 85018-7269 

5. I served the party 

a. I personally delivered the documents to the party or person authorized to 

receive service of process for the party (1) on:11/8/2017 (2) at: 9:00 AM 

Person who served papers: 

triIVIDE Name: Richard F. Acree LEGAL 

County of Maricopa, MC-5966 

3150 N. 24TH STREET, 0-104 

Phoenix, AZ 85018 

(602) 256.9700 

wwwnationwideasap.com 

The fee for service was: $ 60.60 

Date: N mber 09, 2017 

AZ101111 

P2101111.5-561 

CERTIFICATE OF SERVICE 

(Richard F. Acres) 

Attorney& Party olhoot Money 

Shawna Woner 

Garrey Woner Hoff:nester' 8 Peshek PC 

6611 North Scottsdale Road 

Scottsdale, AZ 85250 

'CLEM-101'B Ma: (480) 483-9700 

/Wormy Am 

I 4 

:t. 

.1 , * LOP -I tt I 01.pe 1 

aiiNOV

t• hilf ( 

. 13 A R, 

fin 9:08 

FILED BY C. CARABA JAL, 

Re NV orfle No.: 

- 5-581 

Insert nOme of Court and Juckial Ugric, and Branch Court: 

In MARICOPA COUNTY SUPERIOR COURT in and for the County of MARICOPA 

Peffocer Maricopa Country Special Health Care District, a body politic, governing body for and doing 

business as Maricopa Intergrated Health System, 

Respondent Lexington Insurance Company, a foreign capital stock Insurance company, and AIG Claims, 

Inc., a foreign corporation, et al., 

CERTIFICATE OF SERVICE 

HEARING DATE: TlAIE: DEPT.: CASE NUMBER: 

CV2017-054614 

I declare under penalty of perjury under the laws of the State of Arizona that the foregoing Is true and correct. At the time of 

service I was at least 18 years of age and authorized to serve process in this case. 

I served copies of the 2 Sets - Summons to Lexington Insurance Company.; Complaint; Certificate Regarding Compulsory 

Arbitration; Demand for Jury Trial; Request For Production of Documents to All Defendants; Request For Admissions to MG 

Claims, Inc.; Non-Uniform Interrogatories to Defendant AIG Claims, Inc.; Acceptance Fee Check #16977 - $15.00 

a. Party served Lexington Insurance Company do Arizona Department of Insurance 

b. Person Served Elizabeth Villalino - Administrative Assistant III 

Age: 23 yrs. Race: Hispanic Sex: Female Eyes: Brown Height: 5'6 - 6'0 Weight: 130 lbs. Hair: Black 

Address where served: 2910 N 44th St Ste 210 

Phoenix, AZ 85018-7269 

5. I served the party 

a. I personally delivered the documents to the party or person authorized to 

receive service of process for the party (1) on:11/8/2017 (2) at: 9:00 AM 

Person who served papers: 

triIVIDE Name: Richard F. Acree LEGAL 

County of Maricopa, MC-5966 

3150 N. 24TH STREET, 0-104 

Phoenix, AZ 85018 

(602) 256.9700 

wwwnationwideasap.com 

The fee for service was: $ 60.60 

Date: N mber 09, 2017 

AZ101111 

P2101111.5-561 

CERTIFICATE OF SERVICE 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 24 of 33
Attorney Os Party's:Shad Mooney: 

Shama Woner 

Garrey Woner Hoffmaster 8 Peshek PC 

6611 North Scottsdale Road . MICHAEL Scottsdale, AZ 85250 

TELEPHONE At : (480) 483-9700 

Aff,emey.: 

K 4 C(; 

...,i. i? gf 

, 

16ij f Ref No. tmfda MB: 

5-551 2817 NOV -.... 

2 

Insert name dCoot end Judidal DIM/Ward Stench Coot _ PM 12: 23 

In MARICOPA COUNTY SUPERIOR COURT In and fer thd County of MARICOPA 

Parlour Madcopa Country Special Health Care District, a body politic, governing body for and doing 

business as Maricopa Intergrated Health System, 

I FILED ay a cARABAsed. 

Respondent Lexington Insurance Company, a foreigh capital stock insurance company, and AIG Claims, 

Inc., a foreign corporation, et al, 

HEARING DATE: TIME DEPT.: CASE NUMBER 

CERTIFICATE OF SERVICE CV2017-054614 

I declare under penalty of perjury under the laws of the State of Arizona that the foregoing is true and correct. At the time of 

service I was at least 18 years of age and authorized to serve process in this case. 

I served copies of the SuMmons to Lexington Insurance Company, Complaint, Certificate Regarding Compulsory Arbitration, 

Demand for Jury Trial, Request For Production of Documents to All Defendants, Request For Admissions to Lexington 

Insurance Company, Non-Uniform Interrogatories to Defendant Lexington Insurance Company 

a. Party served Lexington Insurance Company do Legal Department 

b. Person Served Mike Bbrek - Legal Department 

Age: 35 yrs. Race: Caucasiin Sex: Male Eyes: Height: 60" Weight: 175 lbs. Hair: Brown 

Address Where served: 99 High St 

Boston; MA 02110-2320 

5. I served the party 

a. I personally delivered the documents to the party or person authorized to 

receive service of process frit the party (1) on: 11/10/2017 (2) at: 10:40 AM 

Person who served papers: 

itolimi Name: John Rymqzewski 

County of Suffolk, The fee for service was: $ 114.60 

3150 N. 24TH STREET, D-104 

Phoenix, AZ 850161 

(602) 256.9700 

www.nationwideas0.com 

Date: November 13, 2017 

AZ101243 

AZ101243.5-561 

CERTIFICATE OF SERVICE 

Attorney Os Party's:Shad Mooney: 

Shama Woner 

Garrey Woner Hoffmaster 8 Peshek PC 

6611 North Scottsdale Road . MICHAEL Scottsdale, AZ 85250 

TELEPHONE At : (480) 483-9700 

Aff,emey.: 

K 4 C(; 

...,i. i? gf 

, 

16ij f Ref No. tmfda MB: 

5-551 2817 NOV -.... 

2 

Insert name dCoot end Judidal DIM/Ward Stench Coot _ PM 12: 23 

In MARICOPA COUNTY SUPERIOR COURT In and fer thd County of MARICOPA 

Parlour Madcopa Country Special Health Care District, a body politic, governing body for and doing 

business as Maricopa Intergrated Health System, 

I FILED ay a cARABAsed. 

Respondent Lexington Insurance Company, a foreigh capital stock insurance company, and AIG Claims, 

Inc., a foreign corporation, et al, 

HEARING DATE: TIME DEPT.: CASE NUMBER 

CERTIFICATE OF SERVICE CV2017-054614 

I declare under penalty of perjury under the laws of the State of Arizona that the foregoing is true and correct. At the time of 

service I was at least 18 years of age and authorized to serve process in this case. 

I served copies of the SuMmons to Lexington Insurance Company, Complaint, Certificate Regarding Compulsory Arbitration, 

Demand for Jury Trial, Request For Production of Documents to All Defendants, Request For Admissions to Lexington 

Insurance Company, Non-Uniform Interrogatories to Defendant Lexington Insurance Company 

a. Party served Lexington Insurance Company do Legal Department 

b. Person Served Mike Bbrek - Legal Department 

Age: 35 yrs. Race: Caucasiin Sex: Male Eyes: Height: 60" Weight: 175 lbs. Hair: Brown 

Address Where served: 99 High St 

Boston; MA 02110-2320 

5. I served the party 

a. I personally delivered the documents to the party or person authorized to 

receive service of process frit the party (1) on: 11/10/2017 (2) at: 10:40 AM 

Person who served papers: 

itolimi Name: John Rymqzewski 

County of Suffolk, The fee for service was: $ 114.60 

3150 N. 24TH STREET, D-104 

Phoenix, AZ 850161 

(602) 256.9700 

www.nationwideas0.com 

Date: November 13, 2017 

AZ101243 

AZ101243.5-561 

CERTIFICATE OF SERVICE 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 25 of 33
EXHIBIT “F”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 26 of 33
' 2017 

) 

) 

) 

) 

) 

) 

) 

GARREY, WONER, HOFFMASTER & PESHEK; P.C. 

The Gibraltar Building 

,6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

.(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

.AttOrnpys for Mari(bpa County Special Health Care District 

1 

2 

3 

4 

5 

6 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

7 

8 

MARICOPA COUNTY SPECIAL 

HEALTH CARE DISTRICT, a body 

politic, governing body for and doing 

business as MARICOPA 

INTEGRATED HEALTH SYSTEM, 

Plaintiff, 

No.

--- Ciii46*1 4 

CERTIFICATE REGARDING 

COMPULSORY ARBITRATION 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

) 

) 

) 

) 

) 

LEXINGTON INSURANCE 

COMPANY, a foreign capital stock 

insurance company, and AIG CLAIMS, 

INC., a foreign corporation, ABC 

CORPORATIONS, XYZ 

PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

Defendants. 

The undersigned certifies that the largest award sought by the Plaintiff DOES exceed the 

23 

24 

25 

26 

GARREY, WONER, HOFFMASTER & PESHEK; P.C. 

The Gibraltar Building 

,6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

.(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

.AttOrnpys for Mari(bpa County Special Health Care District 

1 

2 

3 

4 

5 

rz P ' 2017 

6 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

MARICOPA COUNTY SPECIAL 

HEALTH CARE DISTRICT, a body 

politic, governing body for and doing 

business as MARICOPA 

INTEGRATED HEALTH SYSTEM, 

Plaintiff, 

v. 

LEXINGTON INSURANCE 

COMPANY, a foreign capital stock 

insurance company, and AIG CLAIMS, 

INC., a foreign corporation, ABC 

CORPORATIONS, XYZ 

PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

23 

24 

25 

26 

-6546 4 

) No. 

) 

) 

) 

) 

) 

) 

) CERTIFICATE REGARDING 

) COMPULSORY ARBITRATION 

) 

) 

) 

Defendants. 

The undersigned certifies that the largest award sought by the Plaintiff DOES exceed the 

m 

, . .. 

1 GARR.EY, WONER, HOFFMASTER & PESHEK; P.C. 'D117 

2 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

,-' 

~..~,~~~~: ~1~ A, U XU w,,_ 

V 

3 (480) 483-9700 

Shawna Murphy Woner 

4 State Bar N.o. 012948 : - . _ 

swone

_~:'blaw::eoir~: ; 

5 Att~rrie ys for 1VPa ricopa County Special FIealth Care District ~ 

. 

.. 

6 

7 SUPERIOR COURT OF THE STATE OF ARIZONA 

8 IN AND FOR TI-iE COUNTY OF MARICOPA 

9 MARICOPA COUNTY SPECIAL ) No. - 

~ L ~1 . e 1~ Y ~: r 

10 HEALTH CARE DISTRICT, a body ) ~`- GJ ~5.~} 6 14 

politic, governing body for and doing ) 

I 1 business as MARICOPA ) 

INTEGRATED HEALTH SYSTEM; ). 

12 

13 ; Plaintiff, ) 

) CERTIFICATE REGARDING 

14 v;: ` ) COMPULSORY ARBITRATION 

) ' ✓ 

15 LEXINGTON INSURANCE ) 

16 COMPANY, a foreign capital stock ) 

insurance company, and AIG CLAIMS, )- 

, 17 INC., a foreign corporation, ABC ) ' 

CORPORATIONS, XYZ ) 

- 18 PARTNERSHIPS, JOHN DOES I-V, ) _ 

19 arid JANE DOES I-V, ) 

) 

20 Defendants: _ 

.... .... . 

21 

The uindersigned certifies that the largest award sought by the Plaintiff DOES exceed the 22 

23 

24 

25 

26 

, ,, ' 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 27 of 33
2 

1 limit set by Local Rules for compulsory arbitration. This case IS NOT subject to the Uniform 

Rules of Procedure for Arbitration. 

3 

4 

5 RESPECTFULLY submitted this 15th day of September, 2017. 

6 

7 GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

8 

9 

10 By 

11 

12 

13 

a a urphy er 

The Gibraltar Buil ng 

6611 North Scottsdale Road, 

Scottsdale,_ Arizona 85250 

Attorneys 

M 

 for Maficopa CountY Special Health Care District 

aridbia4Intemated 1:1,,e0th System 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

2 

1 limit set by Local Rules for compulsory arbitration. This case IS NOT subject to the Uniform 

Rules of Procedure for Arbitration. 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

RESPECTFULLY submitted this 15th day of September, 2017. 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

By urphy er 

The Gibraltar Buil ng 

6611 North Scottsdale Road, 

Scottsdale,_ Arizona 85250 

Attbtfieys for Maricopa CountY Special Health Care District 

4,4,,MaridOP4 Integrated 1.

100 System 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

~. 

limit set by Local Rules for compulsory arbitration. This case IS NOT subject'to the Uniform ' 

Rules of Procedure for Arbitration. 

. ~ 

RESPECTFULLY submitted this 15th day of September, 2017. 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

, ,~/~ 

, 

~ 

By . ~~~ !ro' = --- - - -- 

: .... ...........: .: 

. ......... . 

. .... 

a tu-P hY 1` : Zer 

The GibraltarbuilcMig 

6611 North Scottsdale Road. 

Scottsdale,_Arizona 85250 

Attoriieys for Mai~icopa C.ounty Special Health Care District 

., -. 

~ ica Nlancopa ntegrated Hen;lth System : 

, _1 

~ 

=2- 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 28 of 33
EXHIBIT “G”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 29 of 33
2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com 

'Attorneys for Maricopa .County Special Health Care District 

• Plaintiff, 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

) No:„. 1.;t4 7 - 6 .k 

) 

) 

) 

) 

MARICOPA COUNTY SPECIAL 

HEALTH CARE DISTRICT, a body 

politic, governing body for and doing 

business as MARICOPA INTEGRATED 

HEALTH SYSTEM, 

) 

) 

) DEMAND FOR JURY TRIAL 

) 

) 

LEXINGTON INSURANCE COMPANY, ) 

a foreign capital stock insurance company, ) 

and AIG CLAIMS, INC., a foreign ) 

corporation, ABC CORPORATIONS, ) 

XYZ PARTNERSHIPS, JOHN DOES I-V, ) 

and JANE DOES I-V, ) 

) 

Defendants. ) 

COMES NOW PLAINTIFF, Maricopa County Special Health Care District, by and through 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

The Gibraltar Building 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

(480) 483-9700 

Shawna Murphy Woner 

State Bar No. 012948 

swoner@gwhplaw.com 

'Attorneys for Marieopa County Special Health Care District 

SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF MARICOPA 

MARICOPA COUNTY SPECIAL No. 

HEALTH CARE DISTRICT, a body 

politic, governing body for and doing 

business as MARICOPA INTEGRATED 

HEALTH SYSTEM, 

) 

• Plaintiff, 

DEMAND FOR JURY TRIAL 

LEXINGTON INSURANCE COMPANY, 

a foreign capital stock insurance company, 

and AIG CLAIMS, INC., a foreign 

corporation, ABC CORPORATIONS, 

XYZ PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

Defendants. 

COMES NOW PLAINTIFF, Maricopa County Special Health Care District, by and through 

/// 

// / 

/ / / 

/ / / 

/ / / 

/ / / 

-V. j 

Al& ."W" AV 

I GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

.The Gibraltar Building 

2 6611 North Scottsdale Road C LERK 

Scottsdale, Arizona 85250 P- I 3 (480) 483-9700 

Shawna Murphy Woner 

4 State Bar No. 012948 

swoner,t'gwhplawcom. 

5 Attorh - cys:-.fQr KaricopaCounty Special Health Care District 

6 

7 SUPERIOR COURT OF THE STATE OF ARIZONA 

8 rN AND FOR THE COUNTY OF MARICOPA 

U7 

9 MARICOPA COUNTY SPECIAL No;,. u Z) 

HEALTH CARE DISTRICT, a body 

10 politic, go-veming body for and doing 

11 business as MARICOPA INTEGRATED 

HEALTH SYSTEM, 

12 Plaintiff, 

13 DEMAND FOR JURY TRIAL 

14 

LEXINGTON INSURANCE COMPANY, 

15 a foreign capital stock insurance company, 

16 

and AIG CLAIMS, INC., a foreign 

corporation, ABC CORPORATIONS, 

17 XYZ PARTNERSHIPS, JOHN DOES I-V, 

and JANE DOES I-V, 

18 

Defendants. 

.19 

20 1 CO1\4ES NOW PLAINTIFF, Maricopa County Special Health Care District, by and through 

21 

22 

23 

24 

25 

26 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 30 of 33
1 counsel undersigned, and hereby demands a byliry as to-all remaining triable issues. 

2 

3 RESPECTFULLY submitted this 15th day of September, 2017. 

4 

5 GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

Slatt aMurphy 

The Gibraltar Btu.' g 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

Attorneys for Maricopa County Special Health Care District 

aka Maricopa Integrated Health System 

1 counsel undersigned, and hereby demands aiiiral by luryas to-all remaining triable issues.. 

2 

3 RESPECTFULLY submitted this 15th day of September, 2017. 

4 

5 GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

41 

Leatogiaratiji 

Sha aNurphy. ler 

The Gibraltar BUi g 

6611 North Scottsdale Road 

Scottsdale, Arizona 85250 

Attorneys for Maricopa County Special Health Care District 

aka Maricopa Integrated Health System 

22 

23 

24 

25 

26 

1 counsel undersigned, and hereby demands a: l b.y-Jiiuy as to-all remaining triable issues, 

2 

3 RESPECTFULLY submitted this 15th day of September, 2017: 

4 

5': ; GARREY, WONER, HOFFMASTER & PESHEK, P.C. 

' 6 

7 

8 < ~}~ - . .... ........... : _. .::::.~:~.:- . 

Sha: a.Nlurphy. ie"r :_....._ _ ...;: 

9 The Gibraltar Bui . g; 

6611 North Scottsdale"Road 

10 Scottsdale, Arizona 85250 

Attorneys for Maricopa County Special Health Care District 

11 aka Maricopa Integrated Health System 

12 

* 

~ 

13 

, - 

14 

15 r 

~ 

_ 1 

, :1 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 31 of 33
EXHIBIT “H”

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 32 of 33
Skip To MainContent 

Search 

A WARNING: Bogus Phone Calls, Emails May Lead to Fraud.Read More... 

Civil Court Case Information - Case History 

Case Information 

Case Number. CV2017-054614 Judge: Hannah, John 

File Date: 9/15/2017 Location: Northeast 

Case Type: Civil 

Party Information 

Party Name 

Maricopa County Special Health Care District 

Lexington Insurance Company 

A I G Claims Inc 

Case Documents 

Relationship Sex 

Plaintiff 

Defendant 

Defendant 

Attorney 

Shawna Woner 

Pro Per 

Pro Per 

Filing Date Description Docket Date Filing Party 

11/20/2017 AFS - Affidavit Of Service 11/27/2017 

NOTE: LEXINGTON INSURANCE COMPANY 

11/20/2017 SUM - Summons 11/22/2017 

11/13/2017 SUM - Summons 11/15/2017 

11/1312017 SUM - Summons 11/15/2017 

11/13/2017 AFS - Affldavtt Of Service 11/16/2017 

NOTE: LEXINGTON INSURANCE COMPANY 

11/13/2017 AFS - Affidavit Of Service 11/16/2017 

NOTE: AIG CLAIMS INC 

9/15/2017 COM - Complaint 9/18/2017 

9/15/2017 CCN - Cert Arbitration - Not Subject 9/18/2017 

9/15/2017 CSH - Coversheet 9/18/2017 

9/15/2017 NJT - Not Demand For Jury Trials 9/18/2017 

There are no calendar events on file 

There are no judgments on file 

Case Calendar 

Judgments 

Skip To MainContent 

Search 

A WARNING: Bogus Phone Calls, Emails May Lead to Fraud.Read More... 

Civil Court Case Information - Case History 

Case Information 

Case Number. CV2017-054614 Judge: Hannah, John 

File Date: 9/15/2017 Location: Northeast 

Case Type: Civil 

Party Information 

Party Name 

Maricopa County Special Health Care District 

Lexington Insurance Company 

A I G Claims Inc 

Case Documents 

Relationship Sex 

Plaintiff 

Defendant 

Defendant 

Attorney 

Shawna Woner 

Pro Per 

Pro Per 

Filing Date Description Docket Date Filing Party 

11/20/2017 AFS - Affidavit Of Service 11/27/2017 

NOTE: LEXINGTON INSURANCE COMPANY 

11/20/2017 SUM - Summons 11/22/2017 

11/13/2017 SUM - Summons 11/15/2017 

11/1312017 SUM - Summons 11/15/2017 

11/13/2017 AFS - Affldavtt Of Service 11/16/2017 

NOTE: LEXINGTON INSURANCE COMPANY 

11/13/2017 AFS - Affidavit Of Service 11/16/2017 

NOTE: AIG CLAIMS INC 

9/15/2017 COM - Complaint 9/18/2017 

9/15/2017 CCN - Cert Arbitration - Not Subject 9/18/2017 

9/15/2017 CSH - Coversheet 9/18/2017 

9/15/2017 NJT - Not Demand For Jury Trials 9/18/2017 

There are no calendar events on file 

There are no judgments on file 

Case Calendar 

Judgments 

Case 2:17-cv-04554-SPL Document 1-1 Filed 12/08/17 Page 33 of 33