Preview
Yosef Peretz (SBN 209288)
yperetz@peretzlaw.com
David Garibaldi (SBN 313641)
dgaribaldi@peretzlaw.com
PERETZ & ASSOCIATES
22 Battery Street, Suite 200
San Francisco, CA 94111
Tel: 415.732.3777
Fax: 415.732.3791
ELECTRONICALLY
FILED
Superior Court of Catifornia,
County of San Francisco
02/14/2019
Clerk of the Court
BY: SANDRA SCHIRO-
Deputy Clerk
Attorneys for Plaintiff MARIA ISABEL DELGADO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
MARIA ISABEL DELGADO
Plaintiff,
v.
PRIMERICA LIFE INSURANCE
COMPANY; PRIMERICA FINANCIAL
SERVICES INSURANCE MARKETING,
INC.; AMERICAN INTERNATIONAL
GROUP, INC.; NATIONAL UNION FIRE
INSURANCE COMPANY OF
PITTSBURGH, PA; WELLS FARGO & CO.;
WELLS FARGO BANK, N.A.; WELLS
FARGO INSURANCE, INC. and DOES 2-10,
Defendants.
Case No. CGC-17-559196
VOLUME II OF PLAINTIFF’S INDEX
OF EXHIBITS IN OPPOSITION TO
DEFENDANTS’ MOTIONS FOR
SUMMARY JUDGMENT OR, IN THE
ALTNERATIVE, SUMMARY
ADJUDICATION
RESERVATION NO. 11280228-11
RESERVATION NO. 11300228-07
Date: February 28, 2019
Time: 9:30 a.m.
Dept: 302
RESERVATION NO. 10110301-06
Date: March 1, 2019
Time: 9:30 a.m.
Dept: 302
PLAINTIFF’S INDEX OF EXHIBITS, VOLUME II
-’Blanket Accident Insurance Policy” or “Master Policy,”
contract between National Union and Wells Fargo,
Bates No. NU 0066-73
PLAINTIFF’S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE
ALTNERATIVE, SUMMARY ADJUDICATIONMaster Application for Blanket Accident Insurance Policy”
contract between National Union and Wells Fargo,
Bates No. NU 0001-65
Exhibit 27.000. eeseeeeseensseeereeees Description of Coverage for Blanket Accident Insurance
for Wells Fargo Policy No. 43834560, Bates No.
NU 00417-00425
Exhibit 28.0.0 eeeeeseeseeeeeenes “Voluntary Amendatory Endorsement” for Master Policy
and Master Application, Bates No. NU00754-00755.
EEX it 29 ce tnsetstetetebstessdor dudedstetstabsteberdvebcvtedeietetatabetstesere! National Union Telemarketing Scripts
Bates No. NU 0525-560, 676-689
Exhibit 30... cceceseeseeeesesnesesresesssreucsesseaeesseesssesees Transcript of Customer Service Call dated
December 2, 2006
Exhibit 3b ee eect ceeese cesses eesesereeessesenseneeeensenensee Transcript of Customer Service Call dated
November 2, 2011
EBD Srl lel sletabebehdadedededadodelatehatabehaedededadetodel stele Transcript of Customer Service Call dated
August 9, 2016
Fox Dit 38 ella absbaleceedaasedstatebalalabalelaidedadadatebebal Transcript of Customer Service Call dated
September 15, 2016
Exhibit 34. Transcript of Customer Service Call dated
September 17, 2016
Exhibit 35.00. ccceceeeseseseseseeeceeeceeeceseseseseseeeseseeeeeeee Transcript of Customer Service Call dated
September 17, 2016
BEBE S Greate ta bat bch da dada dadat cb cbcbcbcbeceadodadedatotabeha, Transcript of Customer Service Call dated
September 19, 2016
EXHIDIt 37.0... essscsesecteseenceecseseseeseenesseaesecseeseeeseene Policy Activity Notes for Policy No 43634560
Exhibit 38.0.0... cceeeeeeeeeeseeeeeeeseeseseeaeenenee Transaction Log from LOTS’ Administrative
System for Policy No 43634560
EXHIDIt 39.0... essstescsessossenssseseseesseressseesestesseeeesnets “Welcome Letter,” in English and in Spanish,
from Wells Fargo Bank, N.A., Bates No. NU
413-414
Exhibit 40.00 esesceseeeesesesresesessreneneeee Sales Practices Investigation Report by the Board of
Directors of Wells Fargo & Company,
PLAINTIFF'S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE
ALTNERATIVE, SUMMARY ADJUDICATION
-2-dated April 10, 2017
Exhibit 41 eee cceececeesneeseeneeseeeeeneeneeneenee Marketing Agreement between National Union and
Wells Fargo entities, dated June 1, 2002, and
amendments, Bates No. WF 0001-0158
Exhibit 42.0. esses esesteseesesesesessrsessseessssseeereseenees Wells Fargo Team Member Handbook
Exhibit 430 ee eeceeesreeeneeeeeseeeneenees “Mistakes to Avoid” document from Wells Fargo
Exhibit 44. eccecesceseseeeeeesesesesnaseseeseeeeeeee Excerpt from Description of the Performance
Review Process at Wells Fargo
Exhibit 45. THIS EXHIBIT IS INTENTIONALLY OMITTED
Exhibit 46.00... eceseeteseseeseeeseeeseeteeneneee Medical Records from Queen of the Valley Hospital
Pertaining to Ramiro Alvarez, dated May 29, 2016
Exhibit 47... cscsccsssssssscsessessessnssssssssecsssssnssvsssseseeeea Autopsy Report of Ramiro Alvarez, dated.
September 27, 2016
Exhibit 48 ..Coroner’s Report of Ramiro Alvarez, dated June 9, 2016
Exhibit 4900s tenes Toxicology Report of Ramiro Alvarez, dated June 21, 2016
Exhibit 50.0000 eeeeeeeeeeeeee Life Insurance Policy Issued by Primerica to Delgado and
Alvarez, Bates No. Delgado_POL_000001-038
Exhibit S1o ce eeceseseeeeeeseeeeeesneeneneee Insurance Application Pertaining to Life Insurance
Policy Issued by Primerica to Delgado and
Alvarez, Bates No.
Delgado_Policy_File_000001-012
Exhibit 520.0. esccsesssecsesesessesscsssessesesneseessseenes Insurance Policy Delivery Receipts, Bates No.
Delgado_Policy_File_000041, 000043
Exhibit 53.0.0 tsseseereeneseesseraneneee Insurance Coverage Illustration Receipt, Bates No.
Delgado_Policy_File_42
Exhibit 54.00 eseseeeeneseesesreseenesrenes Denial of Coverage Letter from Primerica to Delgado,
Bates No. Delgado_CLM RT_000009-10
Exhibit 55 Recommendations for San Francisco Superior Court
February 4, 2019 Discovery Calendar by
Judge Pro Tem Chuck Geerhart
PLAINTIFF'S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE
ALTNERATIVE, SUMMARY ADJUDICATION
-3-Exhibit 56 ..Primerica Team Member Basics document
EXHUDit 57.0. ee eeese cesses eeseeneeseeneeseereeseeneeseessesrsneesessseeenseneeneenes Primerica Life Operations Manual
PLAINTIFF'S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE
ALTNERATIVE, SUMMARY ADJUDICATION
-4-EXHIBIT 25AIG Domestic Accident _& Health Division
A Division of Américan International Componits®
NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA.
Executive Offices: 70 Pine Street, Naw. York, NY 10270
(212) 770-7000
(a capital stock company, herein reférred to as the Company)
Palicyholder: Wells Fargo
Policy Number: 9540505
BLANKET ACCIDENT INSURANCE POLICY
This Policy is @ legal contract between the Policyholdér and the Company. The Company agreés to insure
eligible persons of the Pélicyholder against loss covered by this Policy subject to its provisions, limitations and
exclusions. The persons eligible to be insureds. are all persons described in the Classification of Eligible.
Persons section of the.Master Application. This Policy provides accident Insurance to Insuréds whilé they are
participating in Covered Activities.
This Policy is issued in consideration of the payment of the required premium when due and the stalements
set forth.in the sigried Master Application, which is-attached ta.and made part of this Policy.
This Policy begins on the Policy Effective Date Shown in the Master Application and Continues in effect as long.
as premiums are paid when due, unless otherwise terminated as further provided in this Policy. If this Policy is
terminated, insurance ends on the date to which premiums have been paid.
This Policy is govemed by the laws of the state in which it is delivered.
The President and Secretary of National Union Fire insurance Company of Pittsburgh, Pa. witness this Policy:
Hoda ae Me. pak
President Secretary
PLEASE READ THIS POLICY CAREFULLY.
Non-Participating Policy
C11695DBG BSR
NU .0066TABLE OF CONTENTS
wo
Definitions ..
Policy Effective and Termination Dates
Insured's Effective and Termination Dates ....
Premium...
Benefits...
Maximum Amount
Reduction Schedule.
Accidental Death Benefit.
Accidental Dismemberment Benefit
Exposure and Disappearance..
Limitations...
Limitation iple Benefits
Limitation on Multiple Covered Activities .
Exclusions...
Claims Provisions ....
NO HW BHH 4 RAR Bw O
General Provisions......
C11695DBG 2 BSR
NU 0067DEFINITIONS
Any capitalized terms in the Policy, Master Application, and any riders, amendments, or other attached papers
are to be given the meanings as ascribed in this section or as later defined.
Benefit Schedule - means the Benefit Schedule section of the Master Application.
Covered Activity (ies) - means those activities set out in the Covered Activities section of the Master
Application, with respect to which insureds are provided accident insurance under this Policy.
Injury - means bodily injury caused by an accident that: (1) occurs while this Policy is in force as to the person
whose injury is the basis of claim; (2) occurs while such person is participating in a Covered Activity; and (3),
results directly and independently of all other causes in a covered loss.
Insured - means a person: (1) who is a member of an eligible class of persons as described in the
Classification of Eligible Persons section of the Master Application; (2) for whom premium has been paid; and
(3) while covered under this Policy.
immediate Family Member - means a person who is related to the Insured in any of the following ways:
spouse, brother-in-law, sister-inaw, son-in-law, daughter-intaw, mother-in-law, father-in-law, parent (includes
stepparent), brother or sister (includes stepbrother or stepsister), or child (includes legally adopted or
stepchild).
Physician - means a licensed practitioner of the healing arts acting within the scope of his or her license who
is not: 1) the Insured; 2) an Immediate Family Member; or 3) retained by the Policyholder.
POLICY EFFECTIVE AND TERMINATION DATES
Effective Date. This Policy begins on the Policy Effective Date shown in the Master Application at 12:01 AM
Standard Time at the address of the Policyholder where this Policy is delivered.
Termination Date This Policy may, at any time, be terminated by mutual written consent of the Company and
the Policyholder. This Policy terminates automatically on the earlier of: (1) the Policy Termination Date shown
in the Master Application; or (2) the premium due date if premiums are not paid when due. Termination takes
effect at 12:01 AM Standard Time at the Policyholder's address on the date of termination.
INSURED'S EFFECTIVE AND TERMINATION DATES
Effective Date. An insured's coverage under this Policy begins on the latest of: (1) the Policy Effective Date;
(2) the date for which the first premium for the Insured’s coverage is paid; or (3) the date the person becomes
a member of an eligible class of persons as described in the Classification of Eligible Persons section of the
Master Application.
A change in an Insured’s coverage under this Policy due to a change in his or her eligible class or Covered
Activity becomes effective on the later of: (1) when the change in his or her eligible class or Covered Activity
occurs; or (2) if the change requires a change in premium, the date the first changed premium is paid.
However, a change in coverage applies only with respect to accidents that occur once the change becomes
effective.
Termination Date. An Insured's coverage under this Policy ends on the earliest of: (1) the date this Pclicy is
terminated; (2) the premium due date if premiums are not paid when due, or (3) the date the Insured ceases to
be a member of any eligible class(es) of persons as described in the Classification of Eligible Persons section
of the Master Application.
C11695DBG 3 BSR
NU 0068Termination of coverage will not affect a claim for a covered loss that occurred while the Insured’s coverage
was in force under this Policy.
PREMIUM
Premiums. Premiums are payable to the Company at the rates and in the manner described in the Premiums
section of the Master Application. The Company may change the required premiums due on Policy anniversary
date, as measured annually from the Policy Effective Date, Policy anniversary date, by giving the Policyholder
at least 31 days advance wriiten notice. The Company may also change the required premiums at any time
when any change affecting rates is made in this Policy. Any such change in this Policy will not take effect until
any required additional premium is received by the Company, except as otherwise agreed to in writing by the
Company and the Policyholder.)
Grace Period. A Grace Period of 31 days will be provided for the payment of any premium due after the first.
This Policy. will not be terminated fer nonpayment of premium during the Grace Period if the Policyholder pays
all premiums due by the last day of the Grace Period. This Policy will terminate on the last day of the period
for which all premiums have been paid if the Policyholder fails to pay all premiums due by the last day of the
Grace Period.
If the Company expressly agrees to accept late payment of a premium without terminating this Policy, the
Company does so in accordance with the Noncompliance with Policy Requirements provision of the General
Provisions section.
No grace period will be provided if the Company receives notice to terminate this Policy prior to a premium due
date.
BENEFITS
Maximum Amount. As applicable to each Benefit provided by this Policy for each Insured, Maximum Amount
means the amount shown as the maximum amount for that Benefit for the Insured's eligible class in the Benefit
Schedule, subject to the Reductian Schedule shown below.
Reduction Schedule. The Maximum Amount used to determine the amount payable for a loss will be
reduced if an Insured is age 70 or older on the date of the accident causing the loss with respect to any of the
following Benefits provided by this Policy: Accidental Death Benefit, Accidental Dismemberment, Emergency
Accident Benefit, Accidental Medical Expense Benefit, Homecare Banefit, In-Hospital Indemnity Single
Payment Benefit, In-Hospital Indemnity Daily, Payment Benefit Permanent Total Disability Benefit and Family
Leave Benefit. The Maximum Amount is reduced to a percentage of the Maximum Amount that would be used
if the Insured were under age 7( on the date of the accident, according to the following schedule:
AGE ON DATE OF ACCIDENT PERCENTAGE OF UNDER-AGE-70 MAXIMUM AMOUNT
70 50%
Premium for an Insured age 70 or older is based on 100% of the coverage that would be in effect if the Insured
were under age 70. :
“Age” as used above refers to. the age of the Insured on the Insured's most recerit birthday, regardless of the
actual time of birth.
Accidental Death Benefit. If Injury to the Insured results in death within 90 days of the date of the accident
that caused the Injury, the Company will pay 100% of the Maximum Amount.
C11695DBG 4 BSR
NU 0069Accidental Dismemberment Benefit. |f Injury to the Insured results, within 90 days of the date of the
accident that caused the Injury, in any one of the Losses specified below, the Company will pay the
percentage of the Maximum Amount shown below for that Loss?
For Loss of Percentage of Maximum Amount
Both Harids or Both Feet. 100%
Sight of Both Eyes:
One Hand arid’ One-Foot. 00%
One Hand and the Sight of One Ey 100%
One Foot and the Sight of One Eye 100%
Orie Hand or Oné Foot 50%
The. Sight of One Eye. 50%
“Loss” of a hand or foot means complete severance through or above the wrist or ankie joint, "Loss" of sight of
an eye means total:and irrecoverable’ loss of-the entire sight in that eye.
If. more than one Loss is sustained by an Insured as a result of the same accident, ofily one amount, the
largest, will be paid.
Exposure and Disappearance. If by reason of an accident occurring while an Insured's coverage is in force
under this Policy, the Insured is unavoidably éxposed tothe elements and as.a result of such exposure suffers
. a loss for-which a benefitis otherwise payable under this Policy, the loss will be covered under the terms of
this Policy.
If the body of an Insured has not been found within one year of the disappearance, forced landing, stranding,
sinking or wrecking of a conveyance in which the person was an occupant while covered under this Policy,
then it will be deemed, subject to all other terms and provisions of this Policy, that the Insured has suffered
accidental death within the meaning of this Policy.
LIMITATIONS.
Limitation on Multiple Benefits. If an Insured suffers one or more, losses from the same accident for which
amounts are payable under more than one of the following Benefits provided by this Policy, the maximum
amount payable under ail of the Benefits combined will not exceed the amount payable for one of those losses,
the largest: Accidental Death Benefit, Accidental Dismemberment, Emergency Accident Benefit, Accidental
Medical Expensé Benefit, Homecare Benefit, In-Hospital Indemnity Single Payment Benefit, In-Hospital
indemnity Daily, Payment Benefit Permanent Total Disability Benefit and Family Leave Benefit.
Limitation on Multiple Covered Activities. If an Insured Person's Injury is caused by an accident that occurs
while the Insured is.participating in more than one Covered Activity applicabie to that Insured, and if the same
Benefit applies to that Insured with respect to more than ane such Covered Activity, then for Policy purposes
the Maximum Amount for thal Benefit for that Insured for that accident will be determined as though the
accident occurred while the Insured was participating in only one such Covered Activity, the one with the.
largest Maximum Amount for that Benefit for that person:
EXCLUSIONS
This Policy does not cover any loss caused in. whole or in part by, or resulting in whole or in part from, the
following:
4. ‘suicide or any attempt at suicide or intentionally self-inflicted injury or any attempt at intentionally
self-inflicted injury.
C11695DBG 5 BSR
NU 00702. sickness, disease or infections of any kind; except bacterial infections due fo an accidental cut or
wound, botulism or ptomaine poisoning.
3. the Insured’s commission of or.attempt to commit a felony.
4. declared or undeclared war, or any act of declared or undeclared war,
5. participation in any team sport or any other athletic activity, except participation in a Covered Activity.
6. full-time active duty in the armed forces, National Guard or organized reserve corps of any country or
international authority. (Unearned premium for any period for which the Insured is not covered due to
his or her active duty status will be refunded.) (Loss caused while on short-term National Guard or
reserve duty for regularly scheduled training purposes is not excluded.)
7. travel or flight in or on (including getting in or out of, or on. or off of) any vehicle used for aerial
navigation, if the Insured is:
a. tiding as a passenger in any aircraft not licensed for the transportation of passengers for hire.
b. performing, learning to perform or instructing others to perform as a pilot or crew member of any
aircraft.
8. any condition for which the insured is entitled to benefits under any Workers’ Compensation Act or
similar law.
9. the Insured being under the influence. of drugs or intoxicants, unless taken under the advice of a
Physician.
CLAIMS PROVISIONS
Notice of Claim. Written notice of claim must be given to the Company within 20 days after an Insured's loss,
or.as soon thereafter as reasonably possible. Notice given by or on behalf of the claimant to the Company at
American International Companies®, Accident and Health Claims Division, P. O. Box 15701, Wilmington, DE
19850-5701, with information sufficient to identify the Insured, is deemed notice to the Company.
Claim Forms, The Company will send claim forms to the claimant upon receipt of a written notice of claim. If
such forms are not sent within 15 days after the giving of notice, the claimant will be deemed to have met the
proof of loss requirements upon submitting, within the time fixed in this Policy for filing proofs. of loss, written
proof covering the occurrence, the character and the extent of the loss for which claim is made, The notice
should include the Insured's name, the Policyhoider's name and the Policy number.
Proof of Loss. Written proof of loss must be furnished to the Company within 90 days after the date of the
loss. If the loss is one for which this Policy requires continuing eligibility for periodic benefit payments,
subsequent written proofs of eligibility must be furnished at such intervals as the Company may reasonably
require. Failure to furnish proof within the time required neither invalidates nor reduces any claim if it was not
reasonably possible to give proof within such time, provided such proof is furnished as soon as reasonably
possible and in no event, except in the absence of legal capacity of the claimant, later than one year from the
time proof is otherwise required.
Payment of Claims. Upon receipt of due written proof of death, payment for loss of life of an Insured will be
made, in equal shares, to the survivors in the first surviving class of those that follow: the Insured’s (1) spouse;
(2) children; (3) parents; or (4) brothers and sisters. If no class has a survivor, the beneficiary is the Insured's
estate.
C11695DBG 6 BSR.
NU 0071Upon receipt of due written proof of loss, payments for all losses, except loss of life, will be made to (or on
behalf of, if applicable) the Insured suffering the loss. If an Insured dies before all payments due have been
made, the amount still payable will be paid, in equal shares, to the survivors in the first surviving class of those
that follow: the Insured's (1) spouse; (2) children; (3) parents; or (4) brothers and sisters. If no class has a
survivor, the beneficiary is the Insured’s estate.
If any payee is a minor or is not competent to give a valid release for the payment, the payment will be made to
the legal guardian of the payee’s property. If the payee has no legal guardian for his or her property, a
payment not exceeding $1,000 may be made, at the Company's option, to any relative by blood or connection
by marriage of the payee, who, in the Company's opinion, has assumed the custody and support of the minor
or responsibility for the incompetent person's affairs.
Any payment the Company makes in good faith fully discharges the Company's liability to the extent of the
payment made.
Time of Payment of Claims. Benefits payable under this Policy for any loss other than loss for which this
Policy provides any periodic payment will be paid immediately upon the Company's receipt of due written proof
of the loss. Subject to the Company's receipt of due written proof of loss, all accrued benefits for loss for which
this Policy provides periodic payment will be paid at the expiration of each month during the continuance of the
period for which the Company is liable and any balance remaining unpaid upon termination of liability will be
paid immediately upon receipt of such proof.
GENERAL PROVISIONS
Entire Contract; Changes. This Policy, the Master Application, and any attached papers make up the entire
contract between the Policyholder and the Company. In the absence of fraud, all statements made by the
Policyholder or any Insured will be considered representations and not warranties. No written statement made
by an Insured will be used in any contest unless a copy of the statement is furnished to the Insured or his or
her beneficiary or personal representative.
No change in this Policy will be valid until approved by an officer of the Company. The approval must be noted
on or attached to this Policy. No agent may change this Policy or waive any of its provisions.
Incontestability. The validity of this Policy will not be contested after it has been in force for two year(s) from
the Policy Effective Date, except as to nonpayment of premiums.
Physical Examination and Autopsy. The Company at its own expense has the fight and opportunity to
examine the person of any individual whose loss is the basis of claim under this Policy when and as ofien as it
may reasonably require during the pendency of the claim and to make an autopsy in case of death where it is
not forbidden by law.
Legal Actions. No action at law or in equity may be brought to recover on this Policy prior to the expiration of
80 days after written proof of loss has been furnished in accordance with the requirements of this Policy. No
such action may be brought after the expiration of 3 years after the time written proof of loss is required to be
furnished.
Noncompliance with Policy Requirements. Any express waiver by the Company of any requirements of this
Policy will not constitute a continuing waiver of such requirements. Any failure by the Company to insist upon
compliance with any Policy provision will not operate as a waiver or amendment of that provision.
Genformity With State Statutes. Any provision of this Policy which, on its effective date, is in conflict with the
statutes of the state in which this Policy is delivered is hereby amended to conform to the minimum
requirements of those statutes.
C11695DBG 7 BSR
NU 0072Workers’ Compensation. This Policy is not in lieu of and does not affect any requirements for coverage by
any Workers’ Compensation Act or similar law.
Clerical Error. Clerical error, whether by the Policyholder or the Company, will not void the insurance of any
Insured if that insurance would otherwise have been in effect nor extend the insurance of any Insured if that
insurance would otherwise have ended or been reduced as provided in this Policy.
Records. The Company has the right to inspect at any reasonable time, any records of the Policyholder that
may have a bearing on this insurance.
Assignment, An Insured may assign all of his or her rights, privileges and benefits under this Policy. The
Company is not bound by an assignment until the Company receives and files a signed copy. The Company is
not responsible for the validity of assignments. The assignee only takes such rights as the assignor
possessed and such rights are subject to state and federal laws and the terms of this Policy.
New Entrants. This Policy will allow from time to time, that new eligible Insureds of the Policyholder be added
to the class(es) of Insureds originally insured under this Policy.
Misstatement of Age. If premiums for the Insured are based on age and the Insured has misstated his or her
age, there will be a fair adjustment of premiums based on his or her true age. If the benefits for which the
Insured is insured are based on age and the Insured has misstated his or her age, there will be an adjustment
of said benefit based on his or her true age. The Company may require satisfactory proof of age before paying
any claim.
C11695DBG 8 BSR
NU 0073aD oO BF WN
IMAD SALMAN November 29, 2018
DELGADO vs PRIMERICA LIFE INSURANCE 113
to would be eligible for this policy.
Q. Without any kind of signed application;
correct?
A. No, application is not necessary.
Q. Thank you.
MR. CRAVEN: Jeannine, would you
read the answer back. I didn't quite get
it. I think I heard it, but I'm not quite
sure.
(Whereupon, the record was read by
the reporter.)
Q. It was a bit of a double --
A. Double negative.
Q. -- double negative.
A. It's not necessary. So the answer is no.
Q. Got it. Got it. Does National Union have
any document with Mr. Alvarez's signature on it?
A.
his signature on it.
Q.
Ms.
A.
Q.
I. SALMAN
I -- I did not come across documents with
Does National Union have any documents with
Delgado's signature?
I have not seen one.
All right. And would you look at
Z
ESQUIRE 800.211.DEPO (3376)
DEPOSITION SOLUTIONS EsquireSolutions.comaD oO BF WN
IMAD SALMAN November 29, 2018
DELGADO vs PRIMERICA LIFE INSURANCE 114
I. SALMAN
A 28 you said?
Q. Yes, sir. Yeah, 28.
A Okay. I'm there.
Q All right. Can you tell me what Exhibit 28
is?
A. So your question, again, is what is this?
Q. Yes.
A. You know, as it says it's a Policy -- it's
"A legal contract between the Policyholder and the
Company."
Q. All right. And in this case the
policyholder is Wells Fargo; is that correct?
A. That's correct.
Q. Do you know anything further about what
specific legal entity is referred to by Wells Fargo
in Exhibit 28?
A. I'm sorry, repeat that, please.
Q. Yeah. I'm looking on NU66, and I see at
the top of that page or near the top of that page
it says "Policyholder: Wells Fargo."
A. Yes.
Q. And I don't see any further explanation as
to any further detail as to which specific Wells
Fargo entity is the policyholder. And so I was
Zz ESQUIRE 800.211.DEPO (3376)
DEPOSITION SOLUTIONS EsquireSolutions.comEXHIBIT 26AIG Domestic Accident & Health Division
A Division of Amarican International Companies”
NATIONAL UNION FIRE-INSURANCE COMPANY OF PITTSBURGH, PA.
Executive Offices: 70 Pina Street, New York, NY 10270
(212) 770-7000
@ Capital. stock company, herein referred to asthe Company).
MASTER APPLICATION FOR
BLANKET ACCIDENT INSURANCE POLICY
Application is hereby made for 2 plan of accident insurarice based on the follwing statements and representations:
1. Identification of Policyholder:
Namé of Policyholder: Wells Fargo
Address of Policyholder: 7000 Vista Drive
West Des Moines, 1A
Policy Number: 9540505
2 Classification of Eligible Persons:
Class: Description of Class | Number of Eligible Persons 30,000,000
4 All Customers of the Policyholder
2 Eligible Spouses
3 Children of Class | insureds
Eligible Spouse ~ as used above, means the Insured's legal spouse.
Eligible Dependent Child ~ as used above, means the Insured's unmarried child(ren), including natural, step;
foster or adopted children fram the moment of placement inthe home of Insuréd underage 19 (23 if attending an
accredited institution of higher learning on a full time basis)" and primarily dependent on the Insured for support
and maintenance.
SAge of the Dependent Child may. be adjustad-as requirad by state law for residents.of that state.
‘The Definition of Eligible Dependent Child will be expanded to include the following only where required by state
law for residents of that state and may be modified to comply with those state requirements:
Any unmarfied Eligible Dependent Child of the Insured covered under the Policy before reaching the age limit
specified above, who is incapable of self-sustaining self support by reason of mental or physical incapacity,
and
who is primarily dependent on the-Insured for support and-maintenance, may continue to be eligible under the
Policy beyond that age limit for as long as the Policy is in force, but only if they remain continuously covered
under the Policy. The Compahy may request that the Insured submit salisfactory proof of the Eligible Dependent
Child's incapacity and dependericy to the Company within'60 days before the Eligible Dependent Child reaches
the age limit specified above,
If the Insured fails to fuimish thé requested proof before (he Eligible Dependent Child reaches the age
lirnit,
coverage for the Eligible Dependent Child will nét be extended past the age limit. If coverage is extended, the
Company may request that the Insured submit satisfactory proof of the Eligible Dependent Child's continued
incapacity and dependency to the Company on an annual basis. If the Insured fails to furnish the requested proof
Within 31 dzys of the request, coverage ‘for the Eligible Dependent Child will terminate atthe end of that St-day
period,
c11698D8G
BSR
NU 00013. A Policy Coverage: Covered Activities:
1. All activities except while riding as a fare paying passenger on a commercial airline.
B. Benefit Schedule
The Maximum Amounts are used to determine amounts payable under each Benefit. Actual amounts payable will
not exceed the maximums, and may be less than the maximums under circumstances specified in the Policy.
Plan 23J
Benefits Maximum Amount
Ciasst
“Insured
Total Permanent Disability Long Term:
43-482 months (After 12 month waiting period) $10,000"
Total Permanent Disability Short Term: 7-12 months (After 6 month walting period)
Policy Month; 1-3 $2,000*
4-6 $8,000"
7-9 $4,000"
10-12 $5,000"
13-15 $6,000"
16-18 $7,000*
19-21 $8,000"
22-24 $9,000"
25+ $10,000"
Homecare: Months 7-12 (After 6 month waiting
period)
Month: 1-3 $1,000*
4-6 $1,500"
7-9 $2,000"
10-12 $2,500"
13-15 $3,000"
16-18 §3,500*
49-24 $4,000"
22-24 $4,500"
25+ $5,000*
Family Leave Percentage of Salary Limitation 60%
Accidental Dismemberment (AD) Benefit Maximum
$1,000" All Months
Pian 23K
Benefit Maxi mum Ampunt
Gass 7 Gass 2
Acci dental Di sienber neni $7, 000 500
BSR
C11696DBG 2
NU 0002Horecare
(Payable while receiving PTD months 7-12 Benefit)
Policy Month in which injury causing the
disability occurs:
4-6 $1, 000 $500
7-9 $1,500 $750
10-42 $2, 000 $1, 000
13-15 - $2, 500 $1, 250
16-18 $3, 000 $1, 500
19-21 $3, 500 $1, 750
22-24 $4; 000 $2, 000
25+ $4, 500 $2, 250
Percentage of Salary Limitation $5, 000 $2, 500
60% 60%
Permanent Total Usability: Short term (Monthly
Benefit)
Véi ting Period: 6 months; Maxi mum Benefit
Period: 6 months
Policy Month in which injury causing the
disability occurs:
1-3 $2, 000 $1, 000
4-6 $3, 000 $1, 500
7-9 $4, 000 $2, 000
10-12 $5, 000 $2, 500
13-15 $6, 000 $3, 000
16-18 $7,000 $3, 500
19-21 $8, 000 $4, 000
22-24 $9, 000 $4, 500
25+ $10, 000 $5, 000
Permanent Total Ovsability: Long Term (Nonthi y
Benefit) $10, 000 $5, 000
Wai ting Period: 42 months; Maximum Benefit
Period: 120 months
Plan 23M.
Benefit Maxi num
Anount
Gass 1
Accidental Di smenber rent $7, 000
Horecare
eer e while recei ving PTD Benefit months 7-
1
Policy Month in which injury causing the
disability occurs:
1-3 $1,000
4-6 $1, 500
7-9 $2, 000
10-42 $2, 500
13-18 $3, 000
16-18 $3, 500
19-21 $4, 000
22-24 $4,500
25+ $5, 000
Percent age of Salary Limitation 60%
C11696DBG, 3
BSR
NU 0003Permanent Total Disability (Monthly Benefit)
Vai ting Period: 6 months; Maxi mum Benefit
Period: 6 months
Policy Month in which injury causing the
di sabi lity occurs:
-3 $2, 000
4-6 $3, 000
7-9 $4, 000
10-12 $5, 000
13-15 $6, 000
16-18 $7, 000
19-21 $8, 000
22-24 $9, 000
25+ $10, 000
Permanent Total Disability (Nbnthil y Benefit)
Wi ting Period: 12 months; Maximum Benefit $10, 000
Period: 120 Months
Plan_23N
Benefit Maximum Amount
Class 4 Class 2
Accidental Dismemberment $1,000 $500
Homecare
(Payable while receiving PTD Benefit months 7-12)
Policy Month in which injury causing the disability occurs:
1-3 ” $1,000 $500
46 $1,500 $750
7-9 $2,000 $1,000
10-12 $2,500 $1,250
13-15 $3,000 $1,500
16-18 $3,500 $1,750
19-21 $4,000 $2,000
22-24 $4,500 $2,250
25+ $5,000 $2,500
Percentage of Salary Limitation 60% 60%
Permanent Total Disability (Monthly Benefit)
Waiting Period: 6 months; Maximum Benefit Period: 6 months
Policy Month in which injury causing the disability occurs:
1-3 $2,000 $1,000
46 $3,000 $1,500
7-9 $4,000 $2,000
10-12 $5,000 $2,500
13-15 $6,000 $3,000
16-18 $7,000 $3,500
19-21 $8,000 $4,000
22-24 $9,000 $4,500
25+ $10,000 $5,000
Permanent Total Disability (Monthly Benefit)
Waiting Period: 12 months: Maximum Benefit Period: 120 months $10,000 $5,000
Plan 25J
Coverage Amount
Total Permanent Disability
Long Term: Benefit Months 13 - 132 (Afler a 12,Month Waiting Period)
All Policy Months $10,000
Short Term: Months 7-12 (After a 6 Month Waiting Period)
C11696DBG 4
BSR
NU 0004Policy Months 1-3 $2,000
4-6 $3,000
: 7-9 $4,000
10-12 $5,000
13-15 $6,000
16-18 $7,000
19-21 $8,000
22-24 $9,000
25+ $10,000
Homecare
Months 7 - 12 (After a 6 Month Waiting Period)
Policy Months. 1-3 $1,000
4-6 $1,500
7-9 $2,000
10-12 $2,500
13-15 $3,000
16-18 $3,500
19-24 $4,000
22-24 $4,500
25+ $5,000
Percentage of Salary Limitation
for Family Leave 60%
Dismemberment All Policy Months $1,000
Lump Sum Hospitalization No. of Days = 30 $30,000
Daily Hospitalization Days 31 - 180 $1,000
Plan 25K
Benefit ‘Naxi mum Amount
Crass 1 Gass 2
Acci dental Di swenber nent $7, 000 $500
Homecare
(Payable while receiving PTD months 6-12 Benefit)
Policy Month in which injury causing the
disability occurs: $1, 000 $500
1- $1, 500 $750
4-6 $2, 000 $1, 000
7-9 $2, 500 $1, 250
10-12 $3, 000 $1, 500
13-15 $3, 500 $1, 750
16-18 $4, 000 $2, 000
19-24 $4, 500 $2, 250
22-24 $5, 000 $2, 500
25+ 60% 60%
Percentage of Salary Limitation
C11686DBG
a
BSR
NU 0005Th-Fospital Indemnity Osily Benefit
Days: 31-180 $500 $200
Tn-Fospital Tndennity Single Paynent $30, 000 $15, 000
Number_of Days. 0 30
Permanent Total Oi sability (Nonthly Benetit)
Waiting Period: 6 months; Maxi mum Benefit
Period: 6 months
Policy Nonth in which injury causing the $2, 000 $1, 000
disability occurs: $3, 000 $1, 500
= $4,000 $2,000
46 $5, 000 $2, 500
7-9 $6, 000 $3, 000
10-12 $7, 000 $3, 500
13-15 $8, 000 $4, 000
16-18 $9, 000 $4, 500
19-24 $10, 000 $5, 000
22-24
25+
Permanent Total Orsability (Nonthly Benefit) $30, 000 $15, 000
Waiting Period: 13 months; Maximum Benefit 30 30
Period: 120 months
Plan 25M
Benefit Maxi mum Anount,
Gass 1
Accidental Di srenberrent $1, 000
Honecare
{Payal e while receiving PTD Benefit months 7-
Policy Month in which injury causing the
disability ocours:
= $1,000
4-6 $1, 500
7-9 $2, 000
10-12 $2, 500
13-15 $3, 000
16-18 $3, 500
19-24 $4, 000
22-24 $4, 500
25+ $5, 000
Percentage of Salary Linitation 60%
Tn-Hospital Indermity Daily Beneflt
Days: 31-180 $1, 000
Tn- Hospital Indemity Single Paynent $30, GOO
Number of Days 30
| Permanent Total Disability (Nbnthiy Benefit)
Waiting Period: 6 months; Maxi mum Benefit
Period: 6 months
Policy Month in which injury causing the
disability occurs:
le $2, 000
4-6 $3, 000
7-9 $4, 000
10-12 $5, 000
13-15 $6, 000
16-18 $7, 000
19-21 $8, 000
22-24 $9, 000
25+ $10, 000
Permanent Total Disability (Nbnthly Benefit)
Wai ting Period: 12 months; Maxi mum Benefit $10, 000
Period: 120 Months
C11696DBG 6
BSR
NU 0006Plan 25N
Benefit Maximum Amount
Class 4 Class 2
Accidental Dismemberment $1,000. $600
Homecare
(Payable while receiving PTD months 6-12 Benefit)
Policy Month in which Injury ‘causing the disability occurs: :
13 $1,000 $500
46 $1,500 $750
9 $2,000 $1,000
10-12 $2,500 $1,250
13-15 $3,000 $1,500
16:18 $3,500 $1,750
19-21 $4,000 $2,000
22-24 $4,500 $2,250
25+ $5,000 $2,500
Percentage of Salary Limitation 60% 60%
In-Hospital Indemnity Daily Benefit
Days: 31-180 $500 $250
in-Hospital Indemnity Single Payment. $30,000 $15,000
Number.of Days 30 30
Permanent Total Disability (Monthly Benet)
Waiting Period: 6 months; Maximum Bsnefit Period: 6 months
Policy Month in which injury causing the disability occurs:
$2,000 $1,000
$3,000 $1,500
$4,000 $2,000
$5,000 $2,500 >
$6,000 $3,000
$7,000 83,500
$8,000 34,000
$9,000 $4,500
$10,000, $5,000
Permanent Total Disability (Monthly Benefit) $10,000 $5,000
Waiting Period: 13 months; Maximiumn Benefit Period: 132 months 30 30
PLANS 264
Benefits Maximum Amount
Classt
Insured
‘Accidental Death $50,000"
Per Accident Maximum Amount “$50.,.000*
Plan _26C -
Benefit Waxi mum Arount
Primary Tnsured Dependent
Insured Spouse Chitd(ren).
feci dental Di smenbernent $7, 006 $0 0
€116960B6. 7 BSR
NU 0007Honecare
(Payable while receiving PTD Benefit months 7-
12
Waiting Period: 6 months; Maxi mum Benefit
Period: 6 months
Policy-Month in which injury causing the
disability occurs: $1, 000 $0 $0
1-3 $1, 500 30 $0
4-6 $2, 000 $0 $0
7-9 $2, 500 $0 $0
10-12 $3, 000. $0 $0
13-15 $3, 500 $0 $0
416-18 $4,000 $0 $0
19-24 $4, 500 $0 $0
22-24 $5, 000 $0 $0
25+ 60% 0% 0%
Percentage of Sal ary Limitation
Permanent Total Oisability (Nonthly Benefit)
Short Term Benefit Months 7-12
Vai ting Period: 6 months; Maxi mum Benefit
Period: 6 months
Policy Month in which injury causing the
disability occurs:
1-3
4-6 $2, 000 $0 $0
7-9 $3, 000 $0 $0
40-12 $4, 000. $0 $0
43-15 $5, 000 $0 $0
48-18 $6, 000 $0 $0
19-21 $7,000 $0 $0
22-24 $8, 000 $0 SO
25+ $9, 000 $0 $0
$10, 000 $0 $0.
Permanent Total Disability (Monthly Benefit)
Long Term Benefit Months 13-132
Vai ting Period: 12 months; Maxi mum Benefit $10, 000 $0 $0
120 months
ans Visit Benefit (Per Quarter) $50 $25 $25
Family Maximum per Quarter: $50
Family Lifetime Maximum $500
Plan 26D
Benefit Maximum Amount.
Primary Insured Dependent
{insured Spouse Child{ren)
Accidental Dismemberment. $1,000 $500 $0
C11696DBG 8
BSR
NU 0008Homecare
(Payable while receiving PTD Benefit months 7-12)
Waiting Period: 6 months; Maximum Benefit Period: 6 months
Policy Month in which injury causing the disability occurs:
43 : : $1,000 $500 $0
46 $1,500 $750 $0
7 $2,000 $1,000 $0
| 10-42 $2,500 $1,250 $0
13415 $3,000. $1,500 0
16-18 $3,500 $4,750 §0
19-24 $4,000 $2,000 $0
22-24 $4,500 $2,250 90
25+ $5,000 $2,500 $0
Percentage of Salary Limitation %, 60% 0%
Permanent Total Disability (Monthly Benefit)
Short Term: Benefit Months 7-12
Waiting Period: 6 months; Maximuiti Benefit Period: 6 months
Policy Month in which injury causing the disability occiirs:
43 $2,000 $1,000 2
46 $3,000 $1,500
73 $4,000 $2,000 go
10-12 000 $2,500 $0
13-15 $6,000 $3,000 go
4618 $7,000 $3,500 $0
19:21 000 $4,000 $0
22-24 $9,000 $4,500 $0
25+ $10,000 $5,000 $0
Permanent Total Disabllity (Monthly Benefit)
Long Term: Benefit Months 13-132
Walting Period: 12 months; Maximum Benefit Period: 120months _| $10,000 $5,000 $0
Physician's Visit Benefit (Per Quarter) $50 $25 $25
Family Maximum per Quarter: $50
Family Lifetime Maximum: $500
Plan 266
Benefit - iS ‘Maximum Amount
Primary insured
insured Spouse Child(ren)
Accidental Dismemberment. $1,000 $0 $0.
Physician's Visit
Family Maximum No. of Visits Per Quarter: 1
Family Lifetime Maximum: None
Waiting Period: None
Policy Months:
13 $25.00 $26.00 $25.00
46 $27.50 $27.50 $27.50
7 $30.00 $30.00 $30.00
10-42 $32:50 $32.50 $32.50
4345 $35.00 $35.00 $35.00
16-48 $37.50 $37.50 $37.50
19-21 $40.00 $40.00 $40.00
22-24 $42.50 $42.50 $42.50
25-27 $45.00 $45.00 $45.00
28-30 $47.50 $4750 $47.50
at $50.00 $50.00 $50.00
C11G96DBG s
BSR
NU 0009Permanent Total Disabitity (Monthly Benefit)
Short Term: Benefit Months 7-12
Waiting Period: 6 months; Maximum Benefit Period: 6 months
Policy Month in which injury causing the disability occurs:
13 $10,000 $0 $o
46 $11,000 $0 $0
79 $12,000 $0 $0
10-42 $13,000 $0 $0
1815 $14,000 $0 $0
16-18 $15,000 $0 $0
19:21 $16,000 $0 $0
22-24 $17,000 $0 $0
25-27 $48,000. $0 $0
28-30 $19,000 $0 $0
34+ $20,000 $0 $0
Plan 26H
Benefits Waxi rum Amount
Primary Trsured Trsured
Insured Spouse Dependent
Chi | d( ren)
Di srenberrent $7, 000 $500 $0
Total Permanent Oi sabi lity
Valting Period: 6 Nbnths
Waxi tum Number of Nonths: 120
Policy Nonths: 1-3 $70, 000 $5,000 $0
4-6 $11, 000 $5, 500 $0
7-9 $12, 000 $6, 000 $0
10-72 $13, 000 $6, 500 $0
13-15 $74, 000 $7, 000 $0
16-18 $15,000 $7, 500 $0
19-27 $16, 000 $6, 000 $0
2a. 24 S17, 000 $8, 500 $0
25-27 $76,000, $9, 000 $0
28-30 $19, 000 $9, 500 $0
Bit $20, 000, $10, 000 $0
Physician's Visit
Family Maximum 5. of Visits Per
Quarter: 4
Family Lifetine Maximum None
Vai ting Peri od: None
Poll cy Nonths: 1-3 Per Quarter: $25.00 $25, 00 $25.00
a6 $27.50 $27.50 $27.50
7-9 $30.00 $30.00 $30.00
T0- 12 $32.50 $32, 50 $32.50
13-15 $35.00 $35.00 $35.00
16-16 $37.50 $37.50 $37, 50
19-27 $40.00 $40.00 $40.00
22-24 $42. 50. 342.50 $42. 50
25-27 $45.00 $45.00 $45.00
28-30 $47.50 $47.50 $47. 50
STF $50.00 $50. 00 $50.00
Maxi mum Benefit per Accident: $2, 407, 000
C11696DBG
BSR
NU 0010Plan 260
Benefits Maxi num Anount
Pri nary Tnsured Trsured
Insured Spouse Dependent
Chi I d{ ren)
Di srenber rent $1, 000 $500 $0
Total Permanent Disability
Vai ting Perl od: 6 Nonths
Maxi rum Number of Months: 120
Policy Months: 4-3 $10, 000 $5, 000 $0
4-6 $17, 000 $5, 500 $0
75 $12,000 $6, 000 $0
0-72 $13, 000 $6, 500, 10
43-75 $14, 000 $7, 000 $0
16-78 $15, 000 $7, 500 $0
19-27 $16, 000 $8, 000 oo
22-24 $17, 000 38, 500 30
25-27 $78, 000 $9, 000 $0
28-30. $79, 000 $9, 500 $0
31+ $20, 000 $10, 000 $0
Physician's Visit
Family Maximum No. of Visits Per
Quarter: 1
Fanily Lifeline Naxi num None
Vai ting Peri od: None
Policy Months: 1-3 Per Quarter: 325. 00 $25. 00 $25. 00
4-6 $27. 50 $27, 50 $27. 50
7-9 $30.00 $30. 00 $30.00
10-12 $32.50 $32.60 $32.50
13-15 $35. 00 $35. 00 $3.00
16-18 $37.50 $37. 50 $37.50
49-27 $40. 00 $40.00, $40. 00
2-24 $42.50 $42.50 $42.50
25-27 $45- $45_00 $45.00
28-30 347 $47.50 $47.50
3i* $50. 350. 00 $50. 00
Maxi num Benefit per Accident: $2, 401, 000
Plan 26P
Benefit Wax mum Avount
Please Note: If you are 70 yoars of age or
‘older on the date of the covered acci dent
for which benefits are payable, the benoflts
Sisted below wil be reduced by fifty
percent (50%
Primary Tnsur ed
Accidental Of Smenbernent 31, 000
C11696DBG. 11 BSR
NU 0011Permanent Total tisability (Monthly Benefit)
Witing Paricd: 6 months; Maximum Benefit Period: 6 ronths
Policy Month in which Injury causing the disability
occurs:
1-3 $10, 000
4-6 $11, 000
7-9 $12, 000
40-42 $13, 000
43-15 $14, 000
16-18 $15, 000
19-24 $16, 000
22-24 $17, 000
25-27 $18, 000
28-30 $19, 000
31+ $20, 000
Plan 26Q
Benefit Nexium Arount
Please Note:
't you are 70 years of age or
older on the date of the covered accl dont
for which benefits are payable, the benefits
listed below wll be reduced by fifty
percent _( 50%
Primary Trsured Spouse
insured
Rec dent alr srenber nant 31, 000 500.
Permanent Total Osabitity (Nonthry BenelTey
Véiting Period: 6 months; Maximum Benefit Period: 6 months
Policy Month in which Injury causing the disability
occurs:
1-3 $10,000 ‘$5,000
46 $11, 000 $5,500
7-3 $12, 000 ‘$6, 000
40-42 $13, 000 36, 500
43-15 $14; 000 $7; 000
16-18 $15, 000 ‘$7, 500
19-21 $16, 000 $8, 000
22-24 $17, 000 ‘$8, SOO
25-27 $18, 000 $9, 000
28-30 $19, 000 ($9, 500
31+ $20,000. $10, 000.
Plan 26R
Benefit Waxi mum Arount
Cass 7 Gass 2 Gass 3
‘Acci dental_Disnenbernent $1, 000 30 30
Permanent Total Disability (wonthly Benétit)
Vaiting Period: § months; Meximum Benefit Period:
120_ronths
Policy Month in which Injury causing the Disability $10, 000 50 $0
occurs: $11, 000 $0 $0
$12; 000 50 $0
$13, 000 30 $0
$14, 000 $0 SO
$15, 000 $0 $0
$16, 000 $0 $0
$17, 000 50 80
$18, 000 80 50
$19, 000 $0 30
$20, 000 $0 30
C116960BG 12 BSR
NU 0012Physician's Gfice Visit
Maximum Number of Visits per Quarter: 4
Policy Month in which Physician's Ofice Visit
occurs: $25. 00 $25. 00 $25. 00
1-3 $27. 50 $27. 50 $27.50
4-8 $30. 00 $30. 00 $30. 00
7-9 $32. 50 $32. 50 $32. 50
10-12 $35.00 $35. 00 $35. 00
13-15 $37. 50 $37. 50 $37. 50
16-18 $40. 00 $40. 00 $40.00
49-21 $42. 50 $42. 50 $42. 50
22-24 $45, 00 $45. 00 $45. 00
25-27 $47. 50 $47. 50 $47. 50
28-30 $50.00 $50. 00 $50. 00
31+
Plan 26S
Benefit Waxi mum Anount
Gass 1 Gass 2 Gass 3
Reci dental bi srenberrent $7, 000 $800 80
Permanent Total Disability (Monthly Benefit)
Waiting Period: § months; Maxi num Benefit Period:
120 months
Policy Month in which Injury causing the Disability $10,000 $5, 000 30
occurs: $11; 000 $5, 500 SO
4-3 $12,000 $6, 000 $0
4-6 $13, 000 $6, 500 30
7-9 $14, 000 $7, 000 50
10-12 $15, 000 $7, 500 $0
13-15 $16, 000 $8, 000 $0
16-18 $17,000 38, 500 30
19-24 $18, 000 $9, 000 30
22-24 $19, 000 $9, 500 30
25-27 $20, 000 $10, 000 $0
28-30
3t+
Physician's Office Wsit
Maxi mum Nunber of Visits per Quarter: 4
Policy Month in which Physician's Gfice Visit
occurs: $25. 00 $25. 00 $25.00
1:3 $27. 50 $27.50 327.50
4-6 $30. 00 $30. 00 $30. 00
7-9 $32. 50 $32. 50 $32. 50
40-12 $35. 00 $36. 00 $35.00
13-15 $37. 50 $37. 50 $37. 50
16-18 $40. 00 $40. 00 $40.00
19-21 $42. 50 $42. 50 $42.50
22-24 $45.00 $45. 00 $45.00
25-27 $47. 50 47. 50 $47. 50
28-30 $50. 00 $50. 00 $50. 00
3t+
Plan 274
Benefits Maximum Amount
Class |
Insured
Accidental Death $50,000*
Dismemberment $1,000"
Homecare Benefit
Months 7-12 $1,000"
Percentage of Salary 60%
C11696DBG 13 BSR
NU 0013Permanent Total Disability (Monthly Benefit)
Months 7-42 $2,000*
Months 13-132 $10,000"
PLANS 278
Benefits Maximum Amount |
Class! Class It
‘Insured Spouse
Accidental Death $50,000" $0"
Dismemberment $1,000" $500"
Homecare Benefit
‘Months 7-42 $1,000" $500"
Percentage of Salary 60% 60%
Permanent Total Disability (Monthly Banefit)
Months 7-42 $2,000" $1,000"
Months 13-132 $10,000" $5,000"
Maximum Benefit per Accident $4,268,000" $1,268,000"
Plan 28¢
Maximum
Benefits Amount
Class | Class Il Class tlt
insured Spouse Chile
Permanent Total Disability: Months 13—
182 (After 12 month waiting period) $16,000 $0 §o
Permanent Total Disability: Months 7-12
(After 6 month waiting period)
Month: 1=3 $2,000 $0 §0
4~6 $3,000 $0 $0
79 $4,000. $0 $0
40-12 $5,000 $0 $0
13-15 $6,000 $0 $0
46-18 $7,000 $0 $0
19-21 $8,000 $0 $0
22-24 $9,000 $0 $0
25+ $10,000. $0 $0
Homecaré: Months 7-12 (After 6 month
wailing period)
Month: 1-3 $1,000 $0 So
4-6 $1,500 $0 $0
7-9 $2,000 $0 $0
40-12 $2,500 $0 $0
13-15 $3,000 $0 $0
C11696DBG 4
BSR
NU 001416-18 $3,500 $0 $0
19-24 $4,000 $0 $0
22-24 $4,500 $0 $0
25+ $5,000 $0 $0
Family Leave Percentage of Salary
Limitation 60% 60% o%
Accidental Dismemberment (AD)
Sieietalstchcia eed $1,000 All Months. $0 $0
Lump Sum Hospitalization
No. of Days=30 $30,000 a
Daily Hospitalization O°
Days 31-180 $00 $0 §
Physician's Visit Per Quarter
Family Maximum per Quarter: $50
Family Lifetime Maximum: $500 $80 $25 2
Waiting Period: None
Plan 28D
Benefit Maximum
Amount a
‘Glass I
Class! Class Il :
insured ‘Spouse Child
Homecare: Months 7-12 (After 6 month
waiting period)
Month: 1-3 $1,000" $500" $0
4-6 $1,500* $750" $0
7-9 $2,000" $1,000" $0
10-12 $2,500" $1,250* $0
43-15 $3,000* $1,500" $0
16-18 $3,500* $1,750* $0
19-21 $4,000" $2;000* $0
22-24 $4,500" $2,250* $0
25+ $5,000* $2,500* $0
Family Leave Percentage of Salary 7 / fo
Limitation 60% 60% 0%
Accidental Dismemberment (AD) $1,000" All
Benefit Maximum Montes $500*AllMonths — $0*AllMonths
Lump Sum Hospitalization
No.of Days =30 $30,000 $15,000 $0
Daily Hospitalization
Days 31-180 $500 $250 $0
Physician's Visit . Per’ ae
Family Maximum per Quarter: $50
Family Lifetime Maximum: $500 $50 525 825
Waiting Period: None
Pian 286
Benefit Maximum Amount
Class insured | Class 2insured | Class 6 Insured
Spouse Dependent
Child{ren)
‘Aecidental Dismemberment $7,000 0 $0
C11696DBG 15 BSR
NU 0015in-Hospital indemnity Daily Benefit Maximum No. of Days: 150
Policy Month in which Injury causing the Hospitalization occurs:
1-3 $1,009
Preview
Yosef Peretz (SBN 209288) yperetz@peretzlaw.com David Garibaldi (SBN 313641) dgaribaldi@peretzlaw.com PERETZ & ASSOCIATES 22 Battery Street, Suite 200 San Francisco, CA 94111 Tel: 415.732.3777 Fax: 415.732.3791 ELECTRONICALLY FILED Superior Court of Catifornia, County of San Francisco 02/14/2019 Clerk of the Court BY: SANDRA SCHIRO- Deputy Clerk Attorneys for Plaintiff MARIA ISABEL DELGADO SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO MARIA ISABEL DELGADO Plaintiff, v. PRIMERICA LIFE INSURANCE COMPANY; PRIMERICA FINANCIAL SERVICES INSURANCE MARKETING, INC.; AMERICAN INTERNATIONAL GROUP, INC.; NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA; WELLS FARGO & CO.; WELLS FARGO BANK, N.A.; WELLS FARGO INSURANCE, INC. and DOES 2-10, Defendants. Case No. CGC-17-559196 VOLUME II OF PLAINTIFF’S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE ALTNERATIVE, SUMMARY ADJUDICATION RESERVATION NO. 11280228-11 RESERVATION NO. 11300228-07 Date: February 28, 2019 Time: 9:30 a.m. Dept: 302 RESERVATION NO. 10110301-06 Date: March 1, 2019 Time: 9:30 a.m. Dept: 302 PLAINTIFF’S INDEX OF EXHIBITS, VOLUME II -’Blanket Accident Insurance Policy” or “Master Policy,” contract between National Union and Wells Fargo, Bates No. NU 0066-73 PLAINTIFF’S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE ALTNERATIVE, SUMMARY ADJUDICATIONMaster Application for Blanket Accident Insurance Policy” contract between National Union and Wells Fargo, Bates No. NU 0001-65 Exhibit 27.000. eeseeeeseensseeereeees Description of Coverage for Blanket Accident Insurance for Wells Fargo Policy No. 43834560, Bates No. NU 00417-00425 Exhibit 28.0.0 eeeeeseeseeeeeenes “Voluntary Amendatory Endorsement” for Master Policy and Master Application, Bates No. NU00754-00755. EEX it 29 ce tnsetstetetebstessdor dudedstetstabsteberdvebcvtedeietetatabetstesere! National Union Telemarketing Scripts Bates No. NU 0525-560, 676-689 Exhibit 30... cceceseeseeeesesnesesresesssreucsesseaeesseesssesees Transcript of Customer Service Call dated December 2, 2006 Exhibit 3b ee eect ceeese cesses eesesereeessesenseneeeensenensee Transcript of Customer Service Call dated November 2, 2011 EBD Srl lel sletabebehdadedededadodelatehatabehaedededadetodel stele Transcript of Customer Service Call dated August 9, 2016 Fox Dit 38 ella absbaleceedaasedstatebalalabalelaidedadadatebebal Transcript of Customer Service Call dated September 15, 2016 Exhibit 34. Transcript of Customer Service Call dated September 17, 2016 Exhibit 35.00. ccceceeeseseseseseeeceeeceeeceseseseseseeeseseeeeeeee Transcript of Customer Service Call dated September 17, 2016 BEBE S Greate ta bat bch da dada dadat cb cbcbcbcbeceadodadedatotabeha, Transcript of Customer Service Call dated September 19, 2016 EXHIDIt 37.0... essscsesecteseenceecseseseeseenesseaesecseeseeeseene Policy Activity Notes for Policy No 43634560 Exhibit 38.0.0... cceeeeeeeeeeseeeeeeeseeseseeaeenenee Transaction Log from LOTS’ Administrative System for Policy No 43634560 EXHIDIt 39.0... essstescsessossenssseseseesseressseesestesseeeesnets “Welcome Letter,” in English and in Spanish, from Wells Fargo Bank, N.A., Bates No. NU 413-414 Exhibit 40.00 esesceseeeesesesresesessreneneeee Sales Practices Investigation Report by the Board of Directors of Wells Fargo & Company, PLAINTIFF'S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE ALTNERATIVE, SUMMARY ADJUDICATION -2-dated April 10, 2017 Exhibit 41 eee cceececeesneeseeneeseeeeeneeneeneenee Marketing Agreement between National Union and Wells Fargo entities, dated June 1, 2002, and amendments, Bates No. WF 0001-0158 Exhibit 42.0. esses esesteseesesesesessrsessseessssseeereseenees Wells Fargo Team Member Handbook Exhibit 430 ee eeceeesreeeneeeeeseeeneenees “Mistakes to Avoid” document from Wells Fargo Exhibit 44. eccecesceseseeeeeesesesesnaseseeseeeeeeee Excerpt from Description of the Performance Review Process at Wells Fargo Exhibit 45. THIS EXHIBIT IS INTENTIONALLY OMITTED Exhibit 46.00... eceseeteseseeseeeseeeseeteeneneee Medical Records from Queen of the Valley Hospital Pertaining to Ramiro Alvarez, dated May 29, 2016 Exhibit 47... cscsccsssssssscsessessessnssssssssecsssssnssvsssseseeeea Autopsy Report of Ramiro Alvarez, dated. September 27, 2016 Exhibit 48 ..Coroner’s Report of Ramiro Alvarez, dated June 9, 2016 Exhibit 4900s tenes Toxicology Report of Ramiro Alvarez, dated June 21, 2016 Exhibit 50.0000 eeeeeeeeeeeeee Life Insurance Policy Issued by Primerica to Delgado and Alvarez, Bates No. Delgado_POL_000001-038 Exhibit S1o ce eeceseseeeeeeseeeeeesneeneneee Insurance Application Pertaining to Life Insurance Policy Issued by Primerica to Delgado and Alvarez, Bates No. Delgado_Policy_File_000001-012 Exhibit 520.0. esccsesssecsesesessesscsssessesesneseessseenes Insurance Policy Delivery Receipts, Bates No. Delgado_Policy_File_000041, 000043 Exhibit 53.0.0 tsseseereeneseesseraneneee Insurance Coverage Illustration Receipt, Bates No. Delgado_Policy_File_42 Exhibit 54.00 eseseeeeneseesesreseenesrenes Denial of Coverage Letter from Primerica to Delgado, Bates No. Delgado_CLM RT_000009-10 Exhibit 55 Recommendations for San Francisco Superior Court February 4, 2019 Discovery Calendar by Judge Pro Tem Chuck Geerhart PLAINTIFF'S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE ALTNERATIVE, SUMMARY ADJUDICATION -3-Exhibit 56 ..Primerica Team Member Basics document EXHUDit 57.0. ee eeese cesses eeseeneeseeneeseereeseeneeseessesrsneesessseeenseneeneenes Primerica Life Operations Manual PLAINTIFF'S INDEX OF EXHIBITS IN OPPOSITION TO DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT OR, IN THE ALTNERATIVE, SUMMARY ADJUDICATION -4-EXHIBIT 25AIG Domestic Accident _& Health Division A Division of Américan International Componits® NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA. Executive Offices: 70 Pine Street, Naw. York, NY 10270 (212) 770-7000 (a capital stock company, herein reférred to as the Company) Palicyholder: Wells Fargo Policy Number: 9540505 BLANKET ACCIDENT INSURANCE POLICY This Policy is @ legal contract between the Policyholdér and the Company. The Company agreés to insure eligible persons of the Pélicyholder against loss covered by this Policy subject to its provisions, limitations and exclusions. The persons eligible to be insureds. are all persons described in the Classification of Eligible. Persons section of the.Master Application. This Policy provides accident Insurance to Insuréds whilé they are participating in Covered Activities. This Policy is issued in consideration of the payment of the required premium when due and the stalements set forth.in the sigried Master Application, which is-attached ta.and made part of this Policy. This Policy begins on the Policy Effective Date Shown in the Master Application and Continues in effect as long. as premiums are paid when due, unless otherwise terminated as further provided in this Policy. If this Policy is terminated, insurance ends on the date to which premiums have been paid. This Policy is govemed by the laws of the state in which it is delivered. The President and Secretary of National Union Fire insurance Company of Pittsburgh, Pa. witness this Policy: Hoda ae Me. pak President Secretary PLEASE READ THIS POLICY CAREFULLY. Non-Participating Policy C11695DBG BSR NU .0066TABLE OF CONTENTS wo Definitions .. Policy Effective and Termination Dates Insured's Effective and Termination Dates .... Premium... Benefits... Maximum Amount Reduction Schedule. Accidental Death Benefit. Accidental Dismemberment Benefit Exposure and Disappearance.. Limitations... Limitation iple Benefits Limitation on Multiple Covered Activities . Exclusions... Claims Provisions .... NO HW BHH 4 RAR Bw O General Provisions...... C11695DBG 2 BSR NU 0067DEFINITIONS Any capitalized terms in the Policy, Master Application, and any riders, amendments, or other attached papers are to be given the meanings as ascribed in this section or as later defined. Benefit Schedule - means the Benefit Schedule section of the Master Application. Covered Activity (ies) - means those activities set out in the Covered Activities section of the Master Application, with respect to which insureds are provided accident insurance under this Policy. Injury - means bodily injury caused by an accident that: (1) occurs while this Policy is in force as to the person whose injury is the basis of claim; (2) occurs while such person is participating in a Covered Activity; and (3), results directly and independently of all other causes in a covered loss. Insured - means a person: (1) who is a member of an eligible class of persons as described in the Classification of Eligible Persons section of the Master Application; (2) for whom premium has been paid; and (3) while covered under this Policy. immediate Family Member - means a person who is related to the Insured in any of the following ways: spouse, brother-in-law, sister-inaw, son-in-law, daughter-intaw, mother-in-law, father-in-law, parent (includes stepparent), brother or sister (includes stepbrother or stepsister), or child (includes legally adopted or stepchild). Physician - means a licensed practitioner of the healing arts acting within the scope of his or her license who is not: 1) the Insured; 2) an Immediate Family Member; or 3) retained by the Policyholder. POLICY EFFECTIVE AND TERMINATION DATES Effective Date. This Policy begins on the Policy Effective Date shown in the Master Application at 12:01 AM Standard Time at the address of the Policyholder where this Policy is delivered. Termination Date This Policy may, at any time, be terminated by mutual written consent of the Company and the Policyholder. This Policy terminates automatically on the earlier of: (1) the Policy Termination Date shown in the Master Application; or (2) the premium due date if premiums are not paid when due. Termination takes effect at 12:01 AM Standard Time at the Policyholder's address on the date of termination. INSURED'S EFFECTIVE AND TERMINATION DATES Effective Date. An insured's coverage under this Policy begins on the latest of: (1) the Policy Effective Date; (2) the date for which the first premium for the Insured’s coverage is paid; or (3) the date the person becomes a member of an eligible class of persons as described in the Classification of Eligible Persons section of the Master Application. A change in an Insured’s coverage under this Policy due to a change in his or her eligible class or Covered Activity becomes effective on the later of: (1) when the change in his or her eligible class or Covered Activity occurs; or (2) if the change requires a change in premium, the date the first changed premium is paid. However, a change in coverage applies only with respect to accidents that occur once the change becomes effective. Termination Date. An Insured's coverage under this Policy ends on the earliest of: (1) the date this Pclicy is terminated; (2) the premium due date if premiums are not paid when due, or (3) the date the Insured ceases to be a member of any eligible class(es) of persons as described in the Classification of Eligible Persons section of the Master Application. C11695DBG 3 BSR NU 0068Termination of coverage will not affect a claim for a covered loss that occurred while the Insured’s coverage was in force under this Policy. PREMIUM Premiums. Premiums are payable to the Company at the rates and in the manner described in the Premiums section of the Master Application. The Company may change the required premiums due on Policy anniversary date, as measured annually from the Policy Effective Date, Policy anniversary date, by giving the Policyholder at least 31 days advance wriiten notice. The Company may also change the required premiums at any time when any change affecting rates is made in this Policy. Any such change in this Policy will not take effect until any required additional premium is received by the Company, except as otherwise agreed to in writing by the Company and the Policyholder.) Grace Period. A Grace Period of 31 days will be provided for the payment of any premium due after the first. This Policy. will not be terminated fer nonpayment of premium during the Grace Period if the Policyholder pays all premiums due by the last day of the Grace Period. This Policy will terminate on the last day of the period for which all premiums have been paid if the Policyholder fails to pay all premiums due by the last day of the Grace Period. If the Company expressly agrees to accept late payment of a premium without terminating this Policy, the Company does so in accordance with the Noncompliance with Policy Requirements provision of the General Provisions section. No grace period will be provided if the Company receives notice to terminate this Policy prior to a premium due date. BENEFITS Maximum Amount. As applicable to each Benefit provided by this Policy for each Insured, Maximum Amount means the amount shown as the maximum amount for that Benefit for the Insured's eligible class in the Benefit Schedule, subject to the Reductian Schedule shown below. Reduction Schedule. The Maximum Amount used to determine the amount payable for a loss will be reduced if an Insured is age 70 or older on the date of the accident causing the loss with respect to any of the following Benefits provided by this Policy: Accidental Death Benefit, Accidental Dismemberment, Emergency Accident Benefit, Accidental Medical Expense Benefit, Homecare Banefit, In-Hospital Indemnity Single Payment Benefit, In-Hospital Indemnity Daily, Payment Benefit Permanent Total Disability Benefit and Family Leave Benefit. The Maximum Amount is reduced to a percentage of the Maximum Amount that would be used if the Insured were under age 7( on the date of the accident, according to the following schedule: AGE ON DATE OF ACCIDENT PERCENTAGE OF UNDER-AGE-70 MAXIMUM AMOUNT 70 50% Premium for an Insured age 70 or older is based on 100% of the coverage that would be in effect if the Insured were under age 70. : “Age” as used above refers to. the age of the Insured on the Insured's most recerit birthday, regardless of the actual time of birth. Accidental Death Benefit. If Injury to the Insured results in death within 90 days of the date of the accident that caused the Injury, the Company will pay 100% of the Maximum Amount. C11695DBG 4 BSR NU 0069Accidental Dismemberment Benefit. |f Injury to the Insured results, within 90 days of the date of the accident that caused the Injury, in any one of the Losses specified below, the Company will pay the percentage of the Maximum Amount shown below for that Loss? For Loss of Percentage of Maximum Amount Both Harids or Both Feet. 100% Sight of Both Eyes: One Hand arid’ One-Foot. 00% One Hand and the Sight of One Ey 100% One Foot and the Sight of One Eye 100% Orie Hand or Oné Foot 50% The. Sight of One Eye. 50% “Loss” of a hand or foot means complete severance through or above the wrist or ankie joint, "Loss" of sight of an eye means total:and irrecoverable’ loss of-the entire sight in that eye. If. more than one Loss is sustained by an Insured as a result of the same accident, ofily one amount, the largest, will be paid. Exposure and Disappearance. If by reason of an accident occurring while an Insured's coverage is in force under this Policy, the Insured is unavoidably éxposed tothe elements and as.a result of such exposure suffers . a loss for-which a benefitis otherwise payable under this Policy, the loss will be covered under the terms of this Policy. If the body of an Insured has not been found within one year of the disappearance, forced landing, stranding, sinking or wrecking of a conveyance in which the person was an occupant while covered under this Policy, then it will be deemed, subject to all other terms and provisions of this Policy, that the Insured has suffered accidental death within the meaning of this Policy. LIMITATIONS. Limitation on Multiple Benefits. If an Insured suffers one or more, losses from the same accident for which amounts are payable under more than one of the following Benefits provided by this Policy, the maximum amount payable under ail of the Benefits combined will not exceed the amount payable for one of those losses, the largest: Accidental Death Benefit, Accidental Dismemberment, Emergency Accident Benefit, Accidental Medical Expensé Benefit, Homecare Benefit, In-Hospital Indemnity Single Payment Benefit, In-Hospital indemnity Daily, Payment Benefit Permanent Total Disability Benefit and Family Leave Benefit. Limitation on Multiple Covered Activities. If an Insured Person's Injury is caused by an accident that occurs while the Insured is.participating in more than one Covered Activity applicabie to that Insured, and if the same Benefit applies to that Insured with respect to more than ane such Covered Activity, then for Policy purposes the Maximum Amount for thal Benefit for that Insured for that accident will be determined as though the accident occurred while the Insured was participating in only one such Covered Activity, the one with the. largest Maximum Amount for that Benefit for that person: EXCLUSIONS This Policy does not cover any loss caused in. whole or in part by, or resulting in whole or in part from, the following: 4. ‘suicide or any attempt at suicide or intentionally self-inflicted injury or any attempt at intentionally self-inflicted injury. C11695DBG 5 BSR NU 00702. sickness, disease or infections of any kind; except bacterial infections due fo an accidental cut or wound, botulism or ptomaine poisoning. 3. the Insured’s commission of or.attempt to commit a felony. 4. declared or undeclared war, or any act of declared or undeclared war, 5. participation in any team sport or any other athletic activity, except participation in a Covered Activity. 6. full-time active duty in the armed forces, National Guard or organized reserve corps of any country or international authority. (Unearned premium for any period for which the Insured is not covered due to his or her active duty status will be refunded.) (Loss caused while on short-term National Guard or reserve duty for regularly scheduled training purposes is not excluded.) 7. travel or flight in or on (including getting in or out of, or on. or off of) any vehicle used for aerial navigation, if the Insured is: a. tiding as a passenger in any aircraft not licensed for the transportation of passengers for hire. b. performing, learning to perform or instructing others to perform as a pilot or crew member of any aircraft. 8. any condition for which the insured is entitled to benefits under any Workers’ Compensation Act or similar law. 9. the Insured being under the influence. of drugs or intoxicants, unless taken under the advice of a Physician. CLAIMS PROVISIONS Notice of Claim. Written notice of claim must be given to the Company within 20 days after an Insured's loss, or.as soon thereafter as reasonably possible. Notice given by or on behalf of the claimant to the Company at American International Companies®, Accident and Health Claims Division, P. O. Box 15701, Wilmington, DE 19850-5701, with information sufficient to identify the Insured, is deemed notice to the Company. Claim Forms, The Company will send claim forms to the claimant upon receipt of a written notice of claim. If such forms are not sent within 15 days after the giving of notice, the claimant will be deemed to have met the proof of loss requirements upon submitting, within the time fixed in this Policy for filing proofs. of loss, written proof covering the occurrence, the character and the extent of the loss for which claim is made, The notice should include the Insured's name, the Policyhoider's name and the Policy number. Proof of Loss. Written proof of loss must be furnished to the Company within 90 days after the date of the loss. If the loss is one for which this Policy requires continuing eligibility for periodic benefit payments, subsequent written proofs of eligibility must be furnished at such intervals as the Company may reasonably require. Failure to furnish proof within the time required neither invalidates nor reduces any claim if it was not reasonably possible to give proof within such time, provided such proof is furnished as soon as reasonably possible and in no event, except in the absence of legal capacity of the claimant, later than one year from the time proof is otherwise required. Payment of Claims. Upon receipt of due written proof of death, payment for loss of life of an Insured will be made, in equal shares, to the survivors in the first surviving class of those that follow: the Insured’s (1) spouse; (2) children; (3) parents; or (4) brothers and sisters. If no class has a survivor, the beneficiary is the Insured's estate. C11695DBG 6 BSR. NU 0071Upon receipt of due written proof of loss, payments for all losses, except loss of life, will be made to (or on behalf of, if applicable) the Insured suffering the loss. If an Insured dies before all payments due have been made, the amount still payable will be paid, in equal shares, to the survivors in the first surviving class of those that follow: the Insured's (1) spouse; (2) children; (3) parents; or (4) brothers and sisters. If no class has a survivor, the beneficiary is the Insured’s estate. If any payee is a minor or is not competent to give a valid release for the payment, the payment will be made to the legal guardian of the payee’s property. If the payee has no legal guardian for his or her property, a payment not exceeding $1,000 may be made, at the Company's option, to any relative by blood or connection by marriage of the payee, who, in the Company's opinion, has assumed the custody and support of the minor or responsibility for the incompetent person's affairs. Any payment the Company makes in good faith fully discharges the Company's liability to the extent of the payment made. Time of Payment of Claims. Benefits payable under this Policy for any loss other than loss for which this Policy provides any periodic payment will be paid immediately upon the Company's receipt of due written proof of the loss. Subject to the Company's receipt of due written proof of loss, all accrued benefits for loss for which this Policy provides periodic payment will be paid at the expiration of each month during the continuance of the period for which the Company is liable and any balance remaining unpaid upon termination of liability will be paid immediately upon receipt of such proof. GENERAL PROVISIONS Entire Contract; Changes. This Policy, the Master Application, and any attached papers make up the entire contract between the Policyholder and the Company. In the absence of fraud, all statements made by the Policyholder or any Insured will be considered representations and not warranties. No written statement made by an Insured will be used in any contest unless a copy of the statement is furnished to the Insured or his or her beneficiary or personal representative. No change in this Policy will be valid until approved by an officer of the Company. The approval must be noted on or attached to this Policy. No agent may change this Policy or waive any of its provisions. Incontestability. The validity of this Policy will not be contested after it has been in force for two year(s) from the Policy Effective Date, except as to nonpayment of premiums. Physical Examination and Autopsy. The Company at its own expense has the fight and opportunity to examine the person of any individual whose loss is the basis of claim under this Policy when and as ofien as it may reasonably require during the pendency of the claim and to make an autopsy in case of death where it is not forbidden by law. Legal Actions. No action at law or in equity may be brought to recover on this Policy prior to the expiration of 80 days after written proof of loss has been furnished in accordance with the requirements of this Policy. No such action may be brought after the expiration of 3 years after the time written proof of loss is required to be furnished. Noncompliance with Policy Requirements. Any express waiver by the Company of any requirements of this Policy will not constitute a continuing waiver of such requirements. Any failure by the Company to insist upon compliance with any Policy provision will not operate as a waiver or amendment of that provision. Genformity With State Statutes. Any provision of this Policy which, on its effective date, is in conflict with the statutes of the state in which this Policy is delivered is hereby amended to conform to the minimum requirements of those statutes. C11695DBG 7 BSR NU 0072Workers’ Compensation. This Policy is not in lieu of and does not affect any requirements for coverage by any Workers’ Compensation Act or similar law. Clerical Error. Clerical error, whether by the Policyholder or the Company, will not void the insurance of any Insured if that insurance would otherwise have been in effect nor extend the insurance of any Insured if that insurance would otherwise have ended or been reduced as provided in this Policy. Records. The Company has the right to inspect at any reasonable time, any records of the Policyholder that may have a bearing on this insurance. Assignment, An Insured may assign all of his or her rights, privileges and benefits under this Policy. The Company is not bound by an assignment until the Company receives and files a signed copy. The Company is not responsible for the validity of assignments. The assignee only takes such rights as the assignor possessed and such rights are subject to state and federal laws and the terms of this Policy. New Entrants. This Policy will allow from time to time, that new eligible Insureds of the Policyholder be added to the class(es) of Insureds originally insured under this Policy. Misstatement of Age. If premiums for the Insured are based on age and the Insured has misstated his or her age, there will be a fair adjustment of premiums based on his or her true age. If the benefits for which the Insured is insured are based on age and the Insured has misstated his or her age, there will be an adjustment of said benefit based on his or her true age. The Company may require satisfactory proof of age before paying any claim. C11695DBG 8 BSR NU 0073aD oO BF WN IMAD SALMAN November 29, 2018 DELGADO vs PRIMERICA LIFE INSURANCE 113 to would be eligible for this policy. Q. Without any kind of signed application; correct? A. No, application is not necessary. Q. Thank you. MR. CRAVEN: Jeannine, would you read the answer back. I didn't quite get it. I think I heard it, but I'm not quite sure. (Whereupon, the record was read by the reporter.) Q. It was a bit of a double -- A. Double negative. Q. -- double negative. A. It's not necessary. So the answer is no. Q. Got it. Got it. Does National Union have any document with Mr. Alvarez's signature on it? A. his signature on it. Q. Ms. A. Q. I. SALMAN I -- I did not come across documents with Does National Union have any documents with Delgado's signature? I have not seen one. All right. And would you look at Z ESQUIRE 800.211.DEPO (3376) DEPOSITION SOLUTIONS EsquireSolutions.comaD oO BF WN IMAD SALMAN November 29, 2018 DELGADO vs PRIMERICA LIFE INSURANCE 114 I. SALMAN A 28 you said? Q. Yes, sir. Yeah, 28. A Okay. I'm there. Q All right. Can you tell me what Exhibit 28 is? A. So your question, again, is what is this? Q. Yes. A. You know, as it says it's a Policy -- it's "A legal contract between the Policyholder and the Company." Q. All right. And in this case the policyholder is Wells Fargo; is that correct? A. That's correct. Q. Do you know anything further about what specific legal entity is referred to by Wells Fargo in Exhibit 28? A. I'm sorry, repeat that, please. Q. Yeah. I'm looking on NU66, and I see at the top of that page or near the top of that page it says "Policyholder: Wells Fargo." A. Yes. Q. And I don't see any further explanation as to any further detail as to which specific Wells Fargo entity is the policyholder. And so I was Zz ESQUIRE 800.211.DEPO (3376) DEPOSITION SOLUTIONS EsquireSolutions.comEXHIBIT 26AIG Domestic Accident & Health Division A Division of Amarican International Companies” NATIONAL UNION FIRE-INSURANCE COMPANY OF PITTSBURGH, PA. Executive Offices: 70 Pina Street, New York, NY 10270 (212) 770-7000 @ Capital. stock company, herein referred to asthe Company). MASTER APPLICATION FOR BLANKET ACCIDENT INSURANCE POLICY Application is hereby made for 2 plan of accident insurarice based on the follwing statements and representations: 1. Identification of Policyholder: Namé of Policyholder: Wells Fargo Address of Policyholder: 7000 Vista Drive West Des Moines, 1A Policy Number: 9540505 2 Classification of Eligible Persons: Class: Description of Class | Number of Eligible Persons 30,000,000 4 All Customers of the Policyholder 2 Eligible Spouses 3 Children of Class | insureds Eligible Spouse ~ as used above, means the Insured's legal spouse. Eligible Dependent Child ~ as used above, means the Insured's unmarried child(ren), including natural, step; foster or adopted children fram the moment of placement inthe home of Insuréd underage 19 (23 if attending an accredited institution of higher learning on a full time basis)" and primarily dependent on the Insured for support and maintenance. SAge of the Dependent Child may. be adjustad-as requirad by state law for residents.of that state. ‘The Definition of Eligible Dependent Child will be expanded to include the following only where required by state law for residents of that state and may be modified to comply with those state requirements: Any unmarfied Eligible Dependent Child of the Insured covered under the Policy before reaching the age limit specified above, who is incapable of self-sustaining self support by reason of mental or physical incapacity, and who is primarily dependent on the-Insured for support and-maintenance, may continue to be eligible under the Policy beyond that age limit for as long as the Policy is in force, but only if they remain continuously covered under the Policy. The Compahy may request that the Insured submit salisfactory proof of the Eligible Dependent Child's incapacity and dependericy to the Company within'60 days before the Eligible Dependent Child reaches the age limit specified above, If the Insured fails to fuimish thé requested proof before (he Eligible Dependent Child reaches the age lirnit, coverage for the Eligible Dependent Child will nét be extended past the age limit. If coverage is extended, the Company may request that the Insured submit satisfactory proof of the Eligible Dependent Child's continued incapacity and dependency to the Company on an annual basis. If the Insured fails to furnish the requested proof Within 31 dzys of the request, coverage ‘for the Eligible Dependent Child will terminate atthe end of that St-day period, c11698D8G BSR NU 00013. A Policy Coverage: Covered Activities: 1. All activities except while riding as a fare paying passenger on a commercial airline. B. Benefit Schedule The Maximum Amounts are used to determine amounts payable under each Benefit. Actual amounts payable will not exceed the maximums, and may be less than the maximums under circumstances specified in the Policy. Plan 23J Benefits Maximum Amount Ciasst “Insured Total Permanent Disability Long Term: 43-482 months (After 12 month waiting period) $10,000" Total Permanent Disability Short Term: 7-12 months (After 6 month walting period) Policy Month; 1-3 $2,000* 4-6 $8,000" 7-9 $4,000" 10-12 $5,000" 13-15 $6,000" 16-18 $7,000* 19-21 $8,000" 22-24 $9,000" 25+ $10,000" Homecare: Months 7-12 (After 6 month waiting period) Month: 1-3 $1,000* 4-6 $1,500" 7-9 $2,000" 10-12 $2,500" 13-15 $3,000" 16-18 §3,500* 49-24 $4,000" 22-24 $4,500" 25+ $5,000* Family Leave Percentage of Salary Limitation 60% Accidental Dismemberment (AD) Benefit Maximum $1,000" All Months Pian 23K Benefit Maxi mum Ampunt Gass 7 Gass 2 Acci dental Di sienber neni $7, 000 500 BSR C11696DBG 2 NU 0002Horecare (Payable while receiving PTD months 7-12 Benefit) Policy Month in which injury causing the disability occurs: 4-6 $1, 000 $500 7-9 $1,500 $750 10-42 $2, 000 $1, 000 13-15 - $2, 500 $1, 250 16-18 $3, 000 $1, 500 19-21 $3, 500 $1, 750 22-24 $4; 000 $2, 000 25+ $4, 500 $2, 250 Percentage of Salary Limitation $5, 000 $2, 500 60% 60% Permanent Total Usability: Short term (Monthly Benefit) Véi ting Period: 6 months; Maxi mum Benefit Period: 6 months Policy Month in which injury causing the disability occurs: 1-3 $2, 000 $1, 000 4-6 $3, 000 $1, 500 7-9 $4, 000 $2, 000 10-12 $5, 000 $2, 500 13-15 $6, 000 $3, 000 16-18 $7,000 $3, 500 19-21 $8, 000 $4, 000 22-24 $9, 000 $4, 500 25+ $10, 000 $5, 000 Permanent Total Ovsability: Long Term (Nonthi y Benefit) $10, 000 $5, 000 Wai ting Period: 42 months; Maximum Benefit Period: 120 months Plan 23M. Benefit Maxi num Anount Gass 1 Accidental Di smenber rent $7, 000 Horecare eer e while recei ving PTD Benefit months 7- 1 Policy Month in which injury causing the disability occurs: 1-3 $1,000 4-6 $1, 500 7-9 $2, 000 10-42 $2, 500 13-18 $3, 000 16-18 $3, 500 19-21 $4, 000 22-24 $4,500 25+ $5, 000 Percent age of Salary Limitation 60% C11696DBG, 3 BSR NU 0003Permanent Total Disability (Monthly Benefit) Vai ting Period: 6 months; Maxi mum Benefit Period: 6 months Policy Month in which injury causing the di sabi lity occurs: -3 $2, 000 4-6 $3, 000 7-9 $4, 000 10-12 $5, 000 13-15 $6, 000 16-18 $7, 000 19-21 $8, 000 22-24 $9, 000 25+ $10, 000 Permanent Total Disability (Nbnthil y Benefit) Wi ting Period: 12 months; Maximum Benefit $10, 000 Period: 120 Months Plan_23N Benefit Maximum Amount Class 4 Class 2 Accidental Dismemberment $1,000 $500 Homecare (Payable while receiving PTD Benefit months 7-12) Policy Month in which injury causing the disability occurs: 1-3 ” $1,000 $500 46 $1,500 $750 7-9 $2,000 $1,000 10-12 $2,500 $1,250 13-15 $3,000 $1,500 16-18 $3,500 $1,750 19-21 $4,000 $2,000 22-24 $4,500 $2,250 25+ $5,000 $2,500 Percentage of Salary Limitation 60% 60% Permanent Total Disability (Monthly Benefit) Waiting Period: 6 months; Maximum Benefit Period: 6 months Policy Month in which injury causing the disability occurs: 1-3 $2,000 $1,000 46 $3,000 $1,500 7-9 $4,000 $2,000 10-12 $5,000 $2,500 13-15 $6,000 $3,000 16-18 $7,000 $3,500 19-21 $8,000 $4,000 22-24 $9,000 $4,500 25+ $10,000 $5,000 Permanent Total Disability (Monthly Benefit) Waiting Period: 12 months: Maximum Benefit Period: 120 months $10,000 $5,000 Plan 25J Coverage Amount Total Permanent Disability Long Term: Benefit Months 13 - 132 (Afler a 12,Month Waiting Period) All Policy Months $10,000 Short Term: Months 7-12 (After a 6 Month Waiting Period) C11696DBG 4 BSR NU 0004Policy Months 1-3 $2,000 4-6 $3,000 : 7-9 $4,000 10-12 $5,000 13-15 $6,000 16-18 $7,000 19-21 $8,000 22-24 $9,000 25+ $10,000 Homecare Months 7 - 12 (After a 6 Month Waiting Period) Policy Months. 1-3 $1,000 4-6 $1,500 7-9 $2,000 10-12 $2,500 13-15 $3,000 16-18 $3,500 19-24 $4,000 22-24 $4,500 25+ $5,000 Percentage of Salary Limitation for Family Leave 60% Dismemberment All Policy Months $1,000 Lump Sum Hospitalization No. of Days = 30 $30,000 Daily Hospitalization Days 31 - 180 $1,000 Plan 25K Benefit ‘Naxi mum Amount Crass 1 Gass 2 Acci dental Di swenber nent $7, 000 $500 Homecare (Payable while receiving PTD months 6-12 Benefit) Policy Month in which injury causing the disability occurs: $1, 000 $500 1- $1, 500 $750 4-6 $2, 000 $1, 000 7-9 $2, 500 $1, 250 10-12 $3, 000 $1, 500 13-15 $3, 500 $1, 750 16-18 $4, 000 $2, 000 19-24 $4, 500 $2, 250 22-24 $5, 000 $2, 500 25+ 60% 60% Percentage of Salary Limitation C11686DBG a BSR NU 0005Th-Fospital Indemnity Osily Benefit Days: 31-180 $500 $200 Tn-Fospital Tndennity Single Paynent $30, 000 $15, 000 Number_of Days. 0 30 Permanent Total Oi sability (Nonthly Benetit) Waiting Period: 6 months; Maxi mum Benefit Period: 6 months Policy Nonth in which injury causing the $2, 000 $1, 000 disability occurs: $3, 000 $1, 500 = $4,000 $2,000 46 $5, 000 $2, 500 7-9 $6, 000 $3, 000 10-12 $7, 000 $3, 500 13-15 $8, 000 $4, 000 16-18 $9, 000 $4, 500 19-24 $10, 000 $5, 000 22-24 25+ Permanent Total Orsability (Nonthly Benefit) $30, 000 $15, 000 Waiting Period: 13 months; Maximum Benefit 30 30 Period: 120 months Plan 25M Benefit Maxi mum Anount, Gass 1 Accidental Di srenberrent $1, 000 Honecare {Payal e while receiving PTD Benefit months 7- Policy Month in which injury causing the disability ocours: = $1,000 4-6 $1, 500 7-9 $2, 000 10-12 $2, 500 13-15 $3, 000 16-18 $3, 500 19-24 $4, 000 22-24 $4, 500 25+ $5, 000 Percentage of Salary Linitation 60% Tn-Hospital Indermity Daily Beneflt Days: 31-180 $1, 000 Tn- Hospital Indemity Single Paynent $30, GOO Number of Days 30 | Permanent Total Disability (Nbnthiy Benefit) Waiting Period: 6 months; Maxi mum Benefit Period: 6 months Policy Month in which injury causing the disability occurs: le $2, 000 4-6 $3, 000 7-9 $4, 000 10-12 $5, 000 13-15 $6, 000 16-18 $7, 000 19-21 $8, 000 22-24 $9, 000 25+ $10, 000 Permanent Total Disability (Nbnthly Benefit) Wai ting Period: 12 months; Maxi mum Benefit $10, 000 Period: 120 Months C11696DBG 6 BSR NU 0006Plan 25N Benefit Maximum Amount Class 4 Class 2 Accidental Dismemberment $1,000. $600 Homecare (Payable while receiving PTD months 6-12 Benefit) Policy Month in which Injury ‘causing the disability occurs: : 13 $1,000 $500 46 $1,500 $750 9 $2,000 $1,000 10-12 $2,500 $1,250 13-15 $3,000 $1,500 16:18 $3,500 $1,750 19-21 $4,000 $2,000 22-24 $4,500 $2,250 25+ $5,000 $2,500 Percentage of Salary Limitation 60% 60% In-Hospital Indemnity Daily Benefit Days: 31-180 $500 $250 in-Hospital Indemnity Single Payment. $30,000 $15,000 Number.of Days 30 30 Permanent Total Disability (Monthly Benet) Waiting Period: 6 months; Maximum Bsnefit Period: 6 months Policy Month in which injury causing the disability occurs: $2,000 $1,000 $3,000 $1,500 $4,000 $2,000 $5,000 $2,500 > $6,000 $3,000 $7,000 83,500 $8,000 34,000 $9,000 $4,500 $10,000, $5,000 Permanent Total Disability (Monthly Benefit) $10,000 $5,000 Waiting Period: 13 months; Maximiumn Benefit Period: 132 months 30 30 PLANS 264 Benefits Maximum Amount Classt Insured ‘Accidental Death $50,000" Per Accident Maximum Amount “$50.,.000* Plan _26C - Benefit Waxi mum Arount Primary Tnsured Dependent Insured Spouse Chitd(ren). feci dental Di smenbernent $7, 006 $0 0 €116960B6. 7 BSR NU 0007Honecare (Payable while receiving PTD Benefit months 7- 12 Waiting Period: 6 months; Maxi mum Benefit Period: 6 months Policy-Month in which injury causing the disability occurs: $1, 000 $0 $0 1-3 $1, 500 30 $0 4-6 $2, 000 $0 $0 7-9 $2, 500 $0 $0 10-12 $3, 000. $0 $0 13-15 $3, 500 $0 $0 416-18 $4,000 $0 $0 19-24 $4, 500 $0 $0 22-24 $5, 000 $0 $0 25+ 60% 0% 0% Percentage of Sal ary Limitation Permanent Total Oisability (Nonthly Benefit) Short Term Benefit Months 7-12 Vai ting Period: 6 months; Maxi mum Benefit Period: 6 months Policy Month in which injury causing the disability occurs: 1-3 4-6 $2, 000 $0 $0 7-9 $3, 000 $0 $0 40-12 $4, 000. $0 $0 43-15 $5, 000 $0 $0 48-18 $6, 000 $0 $0 19-21 $7,000 $0 $0 22-24 $8, 000 $0 SO 25+ $9, 000 $0 $0 $10, 000 $0 $0. Permanent Total Disability (Monthly Benefit) Long Term Benefit Months 13-132 Vai ting Period: 12 months; Maxi mum Benefit $10, 000 $0 $0 120 months ans Visit Benefit (Per Quarter) $50 $25 $25 Family Maximum per Quarter: $50 Family Lifetime Maximum $500 Plan 26D Benefit Maximum Amount. Primary Insured Dependent {insured Spouse Child{ren) Accidental Dismemberment. $1,000 $500 $0 C11696DBG 8 BSR NU 0008Homecare (Payable while receiving PTD Benefit months 7-12) Waiting Period: 6 months; Maximum Benefit Period: 6 months Policy Month in which injury causing the disability occurs: 43 : : $1,000 $500 $0 46 $1,500 $750 $0 7 $2,000 $1,000 $0 | 10-42 $2,500 $1,250 $0 13415 $3,000. $1,500 0 16-18 $3,500 $4,750 §0 19-24 $4,000 $2,000 $0 22-24 $4,500 $2,250 90 25+ $5,000 $2,500 $0 Percentage of Salary Limitation %, 60% 0% Permanent Total Disability (Monthly Benefit) Short Term: Benefit Months 7-12 Waiting Period: 6 months; Maximuiti Benefit Period: 6 months Policy Month in which injury causing the disability occiirs: 43 $2,000 $1,000 2 46 $3,000 $1,500 73 $4,000 $2,000 go 10-12 000 $2,500 $0 13-15 $6,000 $3,000 go 4618 $7,000 $3,500 $0 19:21 000 $4,000 $0 22-24 $9,000 $4,500 $0 25+ $10,000 $5,000 $0 Permanent Total Disabllity (Monthly Benefit) Long Term: Benefit Months 13-132 Walting Period: 12 months; Maximum Benefit Period: 120months _| $10,000 $5,000 $0 Physician's Visit Benefit (Per Quarter) $50 $25 $25 Family Maximum per Quarter: $50 Family Lifetime Maximum: $500 Plan 266 Benefit - iS ‘Maximum Amount Primary insured insured Spouse Child(ren) Accidental Dismemberment. $1,000 $0 $0. Physician's Visit Family Maximum No. of Visits Per Quarter: 1 Family Lifetime Maximum: None Waiting Period: None Policy Months: 13 $25.00 $26.00 $25.00 46 $27.50 $27.50 $27.50 7 $30.00 $30.00 $30.00 10-42 $32:50 $32.50 $32.50 4345 $35.00 $35.00 $35.00 16-48 $37.50 $37.50 $37.50 19-21 $40.00 $40.00 $40.00 22-24 $42.50 $42.50 $42.50 25-27 $45.00 $45.00 $45.00 28-30 $47.50 $4750 $47.50 at $50.00 $50.00 $50.00 C11G96DBG s BSR NU 0009Permanent Total Disabitity (Monthly Benefit) Short Term: Benefit Months 7-12 Waiting Period: 6 months; Maximum Benefit Period: 6 months Policy Month in which injury causing the disability occurs: 13 $10,000 $0 $o 46 $11,000 $0 $0 79 $12,000 $0 $0 10-42 $13,000 $0 $0 1815 $14,000 $0 $0 16-18 $15,000 $0 $0 19:21 $16,000 $0 $0 22-24 $17,000 $0 $0 25-27 $48,000. $0 $0 28-30 $19,000 $0 $0 34+ $20,000 $0 $0 Plan 26H Benefits Waxi rum Amount Primary Trsured Trsured Insured Spouse Dependent Chi | d( ren) Di srenberrent $7, 000 $500 $0 Total Permanent Oi sabi lity Valting Period: 6 Nbnths Waxi tum Number of Nonths: 120 Policy Nonths: 1-3 $70, 000 $5,000 $0 4-6 $11, 000 $5, 500 $0 7-9 $12, 000 $6, 000 $0 10-72 $13, 000 $6, 500 $0 13-15 $74, 000 $7, 000 $0 16-18 $15,000 $7, 500 $0 19-27 $16, 000 $6, 000 $0 2a. 24 S17, 000 $8, 500 $0 25-27 $76,000, $9, 000 $0 28-30 $19, 000 $9, 500 $0 Bit $20, 000, $10, 000 $0 Physician's Visit Family Maximum 5. of Visits Per Quarter: 4 Family Lifetine Maximum None Vai ting Peri od: None Poll cy Nonths: 1-3 Per Quarter: $25.00 $25, 00 $25.00 a6 $27.50 $27.50 $27.50 7-9 $30.00 $30.00 $30.00 T0- 12 $32.50 $32, 50 $32.50 13-15 $35.00 $35.00 $35.00 16-16 $37.50 $37.50 $37, 50 19-27 $40.00 $40.00 $40.00 22-24 $42. 50. 342.50 $42. 50 25-27 $45.00 $45.00 $45.00 28-30 $47.50 $47.50 $47. 50 STF $50.00 $50. 00 $50.00 Maxi mum Benefit per Accident: $2, 407, 000 C11696DBG BSR NU 0010Plan 260 Benefits Maxi num Anount Pri nary Tnsured Trsured Insured Spouse Dependent Chi I d{ ren) Di srenber rent $1, 000 $500 $0 Total Permanent Disability Vai ting Perl od: 6 Nonths Maxi rum Number of Months: 120 Policy Months: 4-3 $10, 000 $5, 000 $0 4-6 $17, 000 $5, 500 $0 75 $12,000 $6, 000 $0 0-72 $13, 000 $6, 500, 10 43-75 $14, 000 $7, 000 $0 16-78 $15, 000 $7, 500 $0 19-27 $16, 000 $8, 000 oo 22-24 $17, 000 38, 500 30 25-27 $78, 000 $9, 000 $0 28-30. $79, 000 $9, 500 $0 31+ $20, 000 $10, 000 $0 Physician's Visit Family Maximum No. of Visits Per Quarter: 1 Fanily Lifeline Naxi num None Vai ting Peri od: None Policy Months: 1-3 Per Quarter: 325. 00 $25. 00 $25. 00 4-6 $27. 50 $27, 50 $27. 50 7-9 $30.00 $30. 00 $30.00 10-12 $32.50 $32.60 $32.50 13-15 $35. 00 $35. 00 $3.00 16-18 $37.50 $37. 50 $37.50 49-27 $40. 00 $40.00, $40. 00 2-24 $42.50 $42.50 $42.50 25-27 $45- $45_00 $45.00 28-30 347 $47.50 $47.50 3i* $50. 350. 00 $50. 00 Maxi num Benefit per Accident: $2, 401, 000 Plan 26P Benefit Wax mum Avount Please Note: If you are 70 yoars of age or ‘older on the date of the covered acci dent for which benefits are payable, the benoflts Sisted below wil be reduced by fifty percent (50% Primary Tnsur ed Accidental Of Smenbernent 31, 000 C11696DBG. 11 BSR NU 0011Permanent Total tisability (Monthly Benefit) Witing Paricd: 6 months; Maximum Benefit Period: 6 ronths Policy Month in which Injury causing the disability occurs: 1-3 $10, 000 4-6 $11, 000 7-9 $12, 000 40-42 $13, 000 43-15 $14, 000 16-18 $15, 000 19-24 $16, 000 22-24 $17, 000 25-27 $18, 000 28-30 $19, 000 31+ $20, 000 Plan 26Q Benefit Nexium Arount Please Note: 't you are 70 years of age or older on the date of the covered accl dont for which benefits are payable, the benefits listed below wll be reduced by fifty percent _( 50% Primary Trsured Spouse insured Rec dent alr srenber nant 31, 000 500. Permanent Total Osabitity (Nonthry BenelTey Véiting Period: 6 months; Maximum Benefit Period: 6 months Policy Month in which Injury causing the disability occurs: 1-3 $10,000 ‘$5,000 46 $11, 000 $5,500 7-3 $12, 000 ‘$6, 000 40-42 $13, 000 36, 500 43-15 $14; 000 $7; 000 16-18 $15, 000 ‘$7, 500 19-21 $16, 000 $8, 000 22-24 $17, 000 ‘$8, SOO 25-27 $18, 000 $9, 000 28-30 $19, 000 ($9, 500 31+ $20,000. $10, 000. Plan 26R Benefit Waxi mum Arount Cass 7 Gass 2 Gass 3 ‘Acci dental_Disnenbernent $1, 000 30 30 Permanent Total Disability (wonthly Benétit) Vaiting Period: § months; Meximum Benefit Period: 120_ronths Policy Month in which Injury causing the Disability $10, 000 50 $0 occurs: $11, 000 $0 $0 $12; 000 50 $0 $13, 000 30 $0 $14, 000 $0 SO $15, 000 $0 $0 $16, 000 $0 $0 $17, 000 50 80 $18, 000 80 50 $19, 000 $0 30 $20, 000 $0 30 C116960BG 12 BSR NU 0012Physician's Gfice Visit Maximum Number of Visits per Quarter: 4 Policy Month in which Physician's Ofice Visit occurs: $25. 00 $25. 00 $25. 00 1-3 $27. 50 $27. 50 $27.50 4-8 $30. 00 $30. 00 $30. 00 7-9 $32. 50 $32. 50 $32. 50 10-12 $35.00 $35. 00 $35. 00 13-15 $37. 50 $37. 50 $37. 50 16-18 $40. 00 $40. 00 $40.00 49-21 $42. 50 $42. 50 $42. 50 22-24 $45, 00 $45. 00 $45. 00 25-27 $47. 50 $47. 50 $47. 50 28-30 $50.00 $50. 00 $50. 00 31+ Plan 26S Benefit Waxi mum Anount Gass 1 Gass 2 Gass 3 Reci dental bi srenberrent $7, 000 $800 80 Permanent Total Disability (Monthly Benefit) Waiting Period: § months; Maxi num Benefit Period: 120 months Policy Month in which Injury causing the Disability $10,000 $5, 000 30 occurs: $11; 000 $5, 500 SO 4-3 $12,000 $6, 000 $0 4-6 $13, 000 $6, 500 30 7-9 $14, 000 $7, 000 50 10-12 $15, 000 $7, 500 $0 13-15 $16, 000 $8, 000 $0 16-18 $17,000 38, 500 30 19-24 $18, 000 $9, 000 30 22-24 $19, 000 $9, 500 30 25-27 $20, 000 $10, 000 $0 28-30 3t+ Physician's Office Wsit Maxi mum Nunber of Visits per Quarter: 4 Policy Month in which Physician's Gfice Visit occurs: $25. 00 $25. 00 $25.00 1:3 $27. 50 $27.50 327.50 4-6 $30. 00 $30. 00 $30. 00 7-9 $32. 50 $32. 50 $32. 50 40-12 $35. 00 $36. 00 $35.00 13-15 $37. 50 $37. 50 $37. 50 16-18 $40. 00 $40. 00 $40.00 19-21 $42. 50 $42. 50 $42.50 22-24 $45.00 $45. 00 $45.00 25-27 $47. 50 47. 50 $47. 50 28-30 $50. 00 $50. 00 $50. 00 3t+ Plan 274 Benefits Maximum Amount Class | Insured Accidental Death $50,000* Dismemberment $1,000" Homecare Benefit Months 7-12 $1,000" Percentage of Salary 60% C11696DBG 13 BSR NU 0013Permanent Total Disability (Monthly Benefit) Months 7-42 $2,000* Months 13-132 $10,000" PLANS 278 Benefits Maximum Amount | Class! Class It ‘Insured Spouse Accidental Death $50,000" $0" Dismemberment $1,000" $500" Homecare Benefit ‘Months 7-42 $1,000" $500" Percentage of Salary 60% 60% Permanent Total Disability (Monthly Banefit) Months 7-42 $2,000" $1,000" Months 13-132 $10,000" $5,000" Maximum Benefit per Accident $4,268,000" $1,268,000" Plan 28¢ Maximum Benefits Amount Class | Class Il Class tlt insured Spouse Chile Permanent Total Disability: Months 13— 182 (After 12 month waiting period) $16,000 $0 §o Permanent Total Disability: Months 7-12 (After 6 month waiting period) Month: 1=3 $2,000 $0 §0 4~6 $3,000 $0 $0 79 $4,000. $0 $0 40-12 $5,000 $0 $0 13-15 $6,000 $0 $0 46-18 $7,000 $0 $0 19-21 $8,000 $0 $0 22-24 $9,000 $0 $0 25+ $10,000. $0 $0 Homecaré: Months 7-12 (After 6 month wailing period) Month: 1-3 $1,000 $0 So 4-6 $1,500 $0 $0 7-9 $2,000 $0 $0 40-12 $2,500 $0 $0 13-15 $3,000 $0 $0 C11696DBG 4 BSR NU 001416-18 $3,500 $0 $0 19-24 $4,000 $0 $0 22-24 $4,500 $0 $0 25+ $5,000 $0 $0 Family Leave Percentage of Salary Limitation 60% 60% o% Accidental Dismemberment (AD) Sieietalstchcia eed $1,000 All Months. $0 $0 Lump Sum Hospitalization No. of Days=30 $30,000 a Daily Hospitalization O° Days 31-180 $00 $0 § Physician's Visit Per Quarter Family Maximum per Quarter: $50 Family Lifetime Maximum: $500 $80 $25 2 Waiting Period: None Plan 28D Benefit Maximum Amount a ‘Glass I Class! Class Il : insured ‘Spouse Child Homecare: Months 7-12 (After 6 month waiting period) Month: 1-3 $1,000" $500" $0 4-6 $1,500* $750" $0 7-9 $2,000" $1,000" $0 10-12 $2,500" $1,250* $0 43-15 $3,000* $1,500" $0 16-18 $3,500* $1,750* $0 19-21 $4,000" $2;000* $0 22-24 $4,500" $2,250* $0 25+ $5,000* $2,500* $0 Family Leave Percentage of Salary 7 / fo Limitation 60% 60% 0% Accidental Dismemberment (AD) $1,000" All Benefit Maximum Montes $500*AllMonths — $0*AllMonths Lump Sum Hospitalization No.of Days =30 $30,000 $15,000 $0 Daily Hospitalization Days 31-180 $500 $250 $0 Physician's Visit . Per’ ae Family Maximum per Quarter: $50 Family Lifetime Maximum: $500 $50 525 825 Waiting Period: None Pian 286 Benefit Maximum Amount Class insured | Class 2insured | Class 6 Insured Spouse Dependent Child{ren) ‘Aecidental Dismemberment $7,000 0 $0 C11696DBG 15 BSR NU 0015in-Hospital indemnity Daily Benefit Maximum No. of Days: 150 Policy Month in which Injury causing the Hospitalization occurs: 1-3 $1,009