Great American Insurance Company v. Revolutionary Productions Inc.

CourtDistrict Court, E.D. California
DecidedAugust 25, 2025
Docket1:24-cv-01001
StatusUnknown

This text of Great American Insurance Company v. Revolutionary Productions Inc. (Great American Insurance Company v. Revolutionary Productions Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Great American Insurance Company v. Revolutionary Productions Inc., (E.D. Cal. 2025).

Opinion

5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF CALIFORNIA 7

8 GREAT AMERICAN INSURANCE Case No. 1:24-cv-01001-SAB COMPANY, 9 FINDINGS AND RECOMMENDATIONS Plaintiff, RECOMMENDING GRANTING IN PART 10 AND DENYING IN PART PLAINTIFF’S v. MOTION FOR DEFAULT JUDGMENT 11 ORDER DIRECTING THE CLERK OF THE REVOLUTIONARY PRODUCTIONS INC., 12 COURT TO RANDOMLY ASSIGN THIS MATTER TO A DISTRICT JUDGE Defendant. 13 ORDER REQUIRING SERVICE ON 14 DEFENDANT WITHIN THREE DAYS

15 (ECF No. 15)

16 OBJECTIONS DUE WITHIN FOURTEEN DAYS 17 18 I. 19 INTRODUCTION 20 Great American Insurance Company (“Plaintiff”) asserts that under an insurance policy 21 issued to Revolutionary Productions Inc., a California corporation also known as Sum of Us 22 Festival (“Defendant”), Plaintiff has no duty to defend or indemnify Defendant with respect to an 23 insurance claim tendered by Defendant arising out of an incident at the 2023 Sum of Us Festival. 24 Because Defendant has not responded to the complaint, Plaintiff now seeks default judgment. No 25 opposition to Plaintiff’s motion was filed. The Court held hearings on the motion on March 5, 26 2025 and March 12, 2025, at which no appearance was made on behalf of Defendant. 27 Following amendment of the Local Rules effective March 1, 2022, a certain percentage of 28 civil cases shall be directly assigned to a Magistrate Judge only, with consent or declination of 1 consent forms due within 90 days from the date of filing of the action. L.R. App. A(m)(1). This 2 action has been directly assigned to a Magistrate Judge only. Not all parties have appeared in this 3 action. Pursuant to 28 U.S.C. § 636(b)(1)(B), Local Rule 302(c)(7), and Local Rule Appendix A, 4 subsection (m), the Court shall direct the Clerk of the Court to assign a District Judge to this 5 action and the Court shall issue these findings and recommendations as to the pending motion for 6 default judgment. 7 Having considered Plaintiff’s motion and supplemental briefing, the declaration and 8 exhibits attached thereto, Defendant’s nonappearance at both hearings, as well as the Court’s file, 9 the Court recommends granting Plaintiff’s motion for default judgment in part and denying the 10 motion in part. 11 II. 12 BACKGROUND 13 A. The Underlying Prelitigation Claim 14 Plaintiff filed this action for declaratory judgment under 28 U.S.C. § 2201(a) to be 15 relieved of any duty to defend or indemnify Defendant under an insurance policy for a 16 prelitigation settlement demand by third party Natalie Noghrey against Defendant for injuries she 17 sustained while attending the Sum of Us Festival (“the Festival”). (ECF No. 1 (“Compl.”).) 18 According to Plaintiff’s complaint, Noghrey was drinking alcohol on the evening of 19 September 15, 2023 while attending the Festival. (Compl. ¶ 20.) The Festival furnished some of 20 the alcohol Noghrey consumed. (Id. at ¶ 25.) Plaintiff provides three receipts for alcohol 21 purchases allegedly made by Noghrey between 8:22 p.m. and 11:46 p.m., each identifying 22 Defendant as the retailer. (Id. at ¶ 26; ECF No. 1-4 at 2-5.) Plaintiff alleges the liquor license for 23 the event was nontransferable and issued to the Social Influence Foundation. (Compl. ¶ 25.) The 24 bartenders on the night of the incident entered into separate written Volunteer Agreements for the 25 Festival with Defendant whereby they agreed to provide services in exchange for free or 26 discounted entry into the Festival. (Id. at ¶¶ 25, 26; ECF No. 1-3 at 1-13.) 1 Plaintiff alleges that

27 1 All references to pagination of specific documents pertain to those as indicated on the upper right corners via the CM/ECF electronic court docketing system. 28 1 Defendant paid the bartenders their bartending tips from the Festival. (Compl. ¶ 26.) 2 As the evening progressed, Festival organizers and staff determined that Noghrey was 3 excessively intoxicated and that she needed to be taken back to her campsite. (Compl. ¶ 22.) 4 When Festival organizer, Nadia Eker, and employee, Iris Triska, attempted to walk Noghrey in 5 the direction of her campsite, Eker and Triska identified a golf cart being driven by employee, 6 Jess Weiner. (Id.) Weiner was transporting another attendee to the medical area. (Id.) Eker and 7 Triska asked Weiner if they could ride on the golf cart to either reach the command center, the 8 medical area, or get as close as possible to Noghrey’s cabin. (Id.) Noghrey claims that Weiner 9 was operating the golf cart while intoxicated. (Id. at ¶ 23; ECF No. 21-2 at 3.) 10 Between approximately 1:20 a.m. and 2:00 a.m. on September 16, 2023, Weiner made a 11 right turn and Noghrey allegedly fell out of the golf cart and hit her head on the pavement, 12 rendering her unconscious. (Compl. ¶ 23.) Noghrey’s claim alleges that she was rushed to the 13 hospital where she stayed under 24-hour care for nearly a month before she was discharged. (Id.) 14 Noghrey claims she has sustained permanent injuries as a result of the incident. (Id.) 15 Noghrey claims that Defendant owed Noghrey a heightened duty standard of care because 16 of her intoxicated state. (Compl. ¶ 24.) Noghrey further claims Defendant breached its 17 heightened duty because Defendant’s employees failed to ensure Noghrey’s safety after they 18 placed her in the golf cart. (Id.) 19 B. Terms of the Policy 20 Plaintiff issued policy number 472-50-34-01 to named insured Sports and Recreation 21 Providers Association for the policy period February 2, 2023 to February 2, 2025 (the “Master 22 Policy”). (ECF No. 1 (“Compl.”) at ¶ 6; ECF No. 1-1 at 6.) Under Certificate of Coverage No. 23 GAS114226 Form 36270 (Ed. 05/18) in connection with the Master Policy (the “Certificate”), 24 Defendant Revolutionary Productions, Inc.: Sum of Us Festival “qualifies as an insured under the 25 Master Policy for the period of September 11, 2023, to September 19, 2023[.]”2 (ECF No. 1 at ¶ 26 10; ECF No. 1-2 at 2-7.) The Certificate provides insurance subject to all its terms, conditions,

27 2 Both the Master Policy and the Certificate are attached to the complaint and form the basis of Plaintiff’s claims. (ECF Nos. 1-1; 1-2.) The Court finds both are incorporated by reference and may be considered. See Coto Settlement 28 v. Eisenberg, 593 F.3d 1031, 1038 (9th Cir. 2010); see also Fed. R. Civ. P. 10(c). 1 and limitations and incorporates the Master Policy by reference. (ECF No. 1-2 at 2.) The 2 Certificate provides that “[c]overage only applies to ‘Certificate Holders’ [i.e., Revolutionary 3 Productions, Inc.: Sum of Us Festival] for whom coverage has been placed in this program and by 4 whom the premiums have been paid. Coverage does not apply to the ‘Policyholder’ [i.e., Sports 5 and Recreation Providers Association].” (Id.) Coverage by the insurance policy was limited to 6 injury or damage caused by and occurring at the Sum of Us Festival. (Id. at 7.) 7 The Certificate affords (1) commercial general liability coverage with limits of insurance 8 of $1,000,000 each “occurrence”3 and in the aggregate, and (2) professional liability coverage 9 with limits of insurance of $1,000,000 each act, error, or omission and in the aggregate. (ECF No. 10 1-2 at 2-3.) Notably, the Certificate indicates “liquor liability” and “hired and non-owned autos” 11 are “Not Covered.” (Id.) 12 1. Commercial General Liability Coverage 13 The Master Policy provides commercial general liability coverage pursuant to Form CG 14 00 01 (Ed. 04/13). (ECF No.

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Great American Insurance Company v. Revolutionary Productions Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/great-american-insurance-company-v-revolutionary-productions-inc-caed-2025.