INTRODUCTION

Plaintiffs’ Complaint asserts these Causes of Action for:

(1) Declaratory Relief;

(2) Violation of Fair Procedure Doctrine;

(3) Intentional Interference with Economic Advantage; and

(4) Negligent Interference with Economic Advantage.

Defendant demurs to each Cause of Action.

COMPLAINT

The Plaintiffs allege that:

Plaintiffs Adams and Main are chiropractors who formed Align Health Center, Inc. in Wilmington, CA to provide chiropractic services to the longshoreman community.

Defendant is an employee-health and welfare benefit plan which provides medical benefits to certain union members.

For six years, Plaintiffs provided chiropractic services for thousands of Defendant’s employee benefit plan recipients (longshoremen).

On May 23, 2016 Plaintiffs received letters from Defendant notifying them that, effective on June 23, 2016, Plaintiffs would no longer receive benefits payments from Defendant.

Despite Plaintiffs’ requests, Defendant never explained the reason for