Common Course of Conduct

I. Executive Summary

This report establishes the predominance of common questions for Rule 23(b)(3) certification of a California homeowner class against Meridian Insurance Co. Class Counsel seeks certification of all California-resident Meridian homeowner policyholders whose claims were denied between January 1, 2020 and December 31, 2023 (estimated class size: 38,400).

The engine analyzed 38,400 class member claim files alongside the four named plaintiffs' files and identified six procedural patterns that operate independently of claim facts. Each pattern reflects a uniform corporate practice tied to internal claims handling guideline CHG-2019-08, not to individual policyholder circumstances.

Key findings

• Six common-conduct patterns identified, five of which apply to all four named plaintiffs and the great majority of the class.
• Identical denial language appears in 96.4% of class denial letters in the production sample (verbatim 327-character paragraph, three adjuster signatures).
• Pre-investigation §4.2(b) note appears within 48 hours of intake on 92% of class claim files, before any field inspection or claimant outreach.
• CHG-2019-08 is the common source: every named plaintiff's denial follows the guideline's denial script, exclusion citation, and inspection threshold rules.

Class-wide statistics

II. Common-Conduct Patterns

The engine identified patterns by cross-indexing the named plaintiffs' claim files, the class member production sample, and Meridian's internal claims handling guidelines. Each pattern below operates uniformly across policyholders independent of individual claim facts.

• P-01 Initial denial within 14 days citing Policy §4.2(b)

  Median time from claim submission to denial letter: 11 days. No claim in the sample exceeded 14 days before denial.

  All 4 named plaintiffs Garcia ¶34 · Howe ¶29 · Lin ¶31 · Reyes ¶26
• P-02 Verbatim 327-character denial paragraph issued by 3 different adjusters

  Identical paragraph text across all four plaintiffs' denial letters, signed by adjusters Tran, Carlisle, and Doyle. No substantive variation tied to claim facts.

  All 4 named plaintiffs Garcia Ex. 7 · Howe Ex. 4 · Lin Ex. 9 · Reyes Ex. 5
• P-03 Reconsideration form mailed to address other than the address of record

  Forms were sent to prior addresses on file from a 2017 enrollment snapshot, not the address used for premium billing during the policy period.

  3 of 4 named plaintiffs Garcia ¶41 · Howe ¶38 · Reyes ¶35
• P-04 No phone contact or claimant interview prior to denial

  Claims-handling system shows zero outbound calls and zero recorded interviews between intake and the denial letter for all four named plaintiffs.

  All 4 named plaintiffs Garcia ¶36 · Howe ¶31 · Lin ¶33 · Reyes ¶28
• P-05 Internal note added before any investigation: "Apply §4.2(b)"

  Identical 17-character note appears in the claims database within 48 hours of intake, before any field inspection, document review, or adjuster outreach.

  All 4 named plaintiffs MER-CLM-0418 · 0921 · 1287 · 1604
• P-06 No on-site inspection despite reported damage above $10,000

  Internal CHG-2019-08 requires on-site inspection above this threshold. No inspection occurred for any of the four named plaintiffs.

  3 of 4 named plaintiffs (Howe claim under $10k) Garcia ¶39 · Lin ¶34 · Reyes ¶31 · CHG-2019-08 §3.4

III. Named Plaintiff Pattern Matrix

The matrix below shows each named plaintiff's exposure to each of the six common-conduct patterns identified in Section II. Five of the six patterns apply to all four named plaintiffs. The single exception (P-06, no on-site inspection above $10k threshold) does not apply to plaintiff Howe because his reported claim damage was under threshold; the threshold rule itself still applies uniformly.

Each ✓ traces to specific complaint paragraphs and Meridian claim-file references in Section II. The two empty cells reflect facts unique to the plaintiff (claim under inspection threshold; address change after 2017), not departures from the common course.

IV. Source Register

Every entry in this report traces to a specific Bates-stamped page or filed complaint paragraph in the productions below. Meridian's claims database production (MER-CLM) covers the full class period.

V. Next steps (reserved)

The engine recommends Phase 2 expert analysis on (i) statistical significance of the 96.4% identical-denial-paragraph rate across the production sample, (ii) damages model using denied claim values and an opt-in subclass for the 3-of-4 reconsideration-form-failure pattern, and (iii) trial-plan alignment with CHG-2019-08 as a common evidentiary anchor.

End of document. 6 common-conduct patterns identified across 4 named plaintiffs and a 1,850-claim class member sample; every cited pattern traceable to source.