Kazazian v. CNA Financial Corporation

CourtDistrict Court, N.D. Illinois
DecidedJuly 18, 2025
Docket1:24-cv-10843
StatusUnknown

This text of Kazazian v. CNA Financial Corporation (Kazazian v. CNA Financial Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kazazian v. CNA Financial Corporation, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

NINA KAZAZIAN, ) Plaintiff, ) ) No. 24-cv-10843 v. ) ) Judge April M. Perry CNA FINANCIAL CORPORATION d/b/a ) CONTINENTAL CASUALTY COMPANY ) d/b/a CNA INSURANCE COMPANIES; ) JEAN L. HAUBER; WILSON, ELSER, ) MOSKOWITZ, EDELMAN & DICKER LLP; ) JASON MELICHAR; and DR. LAURA ) REIFFEL, ) ) Defendants. ) )

OPINION AND ORDER Beginning in 2020, Nina Kazazian (“Plaintiff”) faced a series of attorney disciplinary proceedings in Colorado, where she had practiced since 1992. As a result of those proceedings, Plaintiff was disbarred in 2023. See People v. Kazazian, 531 P.3d 1 (Colo. O.P.D.J. 2023). Plaintiff subsequently brought this case against her malpractice insurance carrier and one of its employees, as well as the law firm, lawyer, and expert hired by the carrier to defend Plaintiff during the disciplinary proceedings. Specifically, Defendants in this case are Plaintiff’s insurance carrier CNA Financial Corporation d/b/a Continental Casualty Company d/b/a CNA Insurance Companies (“CNA”);1 Jean L. Hauber, an employee of CNA; the law firm Wilson, Elser, Moskowitz, Edelman & Dicker LLP (“Wilson Elser”) and partner Jason Melichar, who CNA

1 CNA contends that Plaintiff has sued the incorrect legal entity. Because the Court dismisses the case, it does not need to untangle the various corporate relationships or address which CNA legal entity would be the proper defendant. retained for Plaintiff’s defense; and Dr. Laura Reiffel, an expert retained for Plaintiff’s defense (collectively with Wilson Elser and Melichar, “Counsel Defendants”). Defendants move to dismiss Plaintiff’s claims on various grounds. All seek to dismiss the case for improper venue or under the doctrine of forum non conveniens. Defendants Melichar and Dr. Reiffel also seek dismissal for lack of personal jurisdiction. Multiple defendants also

seek to dismiss certain of Plaintiff’s counts for failure to state a claim under Rule 12(b)(6). While there are weighty challenges to the sufficiency of the complaint, the Court limits its analysis to the threshold issues of personal jurisdiction and venue, which are dispositive. As set forth in greater detail below, the Court finds that while it may have personal jurisdiction over all of the Defendants, the Northern District of Illinois is not the proper venue for this action. Accordingly, the case is dismissed. BACKGROUND According to the complaint, Plaintiff is now a citizen of Wyoming who practiced law in Colorado from 1992 until 2023. Doc. 65 at 4. Beginning in 2020, Plaintiff faced a series of

disciplinary proceedings brought by the Colorado Office of Attorney Regulation Counsel (“OARC”) related to her practice of law. Id. at 14. The first proceeding was initiated in September 2020, and the disciplinary hearing was held in January 2023. Id. In May 2022, another petition was filed by OARC to prevent Plaintiff from practicing law due to an unspecified disability. Id. At all relevant times, Plaintiff held a professional liability insurance policy issued by CNA. Id. at 9–13. Under Plaintiff’s policy, CNA was to provide Plaintiff with counsel to defend her in disciplinary proceedings and reimburse her up to $50,000 in attorneys’ fees and costs for her representation. Id. at 18–19. In June 2022, CNA retained the law firm Wilson Elser and its

2 Colorado-based partner Jason Melichar to represent Plaintiff in the Colorado disciplinary proceedings. Id. at 5–6, 15. Dr. Reiffel was also retained to produce an expert report for Plaintiff’s defense, though no report was produced. Id. at 8, 15, 20. CNA paid Counsel Defendants out of Plaintiff’s policy. To receive payments, Counsel Defendants sent invoices and time records to CNA either by email or through electronic billing

software. Id. at 7. CNA then reviewed the invoices and determined an approved payment amount. Id. at 5–6. This contrasted with the process that had been related to Plaintiff by Hauber, a CNA claims representative. Specifically, Hauber allegedly told Plaintiff that her policy dictated that payments from CNA be issued directly to Plaintiff to reimburse her for costs and fees associated with her representation, rather than being paid by CNA to retained service providers. Id. at 7. While she was represented, Plaintiff never received invoices or statements from any Defendants. Id. at 7-8. Plaintiff instructed Hauber not to make payments to Dr. Reiffel because Dr. Reiffel had failed to deliver an expert report. Id. at 15. Plaintiff also told CNA not to make

payments to Wilson Elser or Melichar until Plaintiff had a chance to personally review the bills and determine the authorized amounts. Id. at 16. In March 2023, Plaintiff was disbarred in Colorado. People v. Kazazian, 531 P.3d 1 (Colo. O.P.D.J. 2023). In October 2024, Plaintiff filed suit in this court, bringing state law claims against CNA and Counsel Defendants for mishandling her defense and depleting her policy benefits. Doc. 1. Defendant Hauber was not named in Plaintiff’s initial complaint. In January 2025, Defendants filed motions to dismiss, to which Plaintiff responded in February by amending her complaint. Doc. 65. Plaintiff’s amended complaint added Hauber as a defendant

3 and also added a claim under the federal Racketeer Influenced and Corrupt Organizations Act (“RICO”). The amended complaint alleges six counts. Count I is a RICO claim brought against all defendants. Id. at 16-18. The gravamen of this claim is that Counsel Defendants sent fraudulent billing records and invoices to CNA for work either not performed or not reasonably incurred for

the purposes of representing Plaintiff in her Colorado disciplinary proceedings. Although brought against all defendants, Plaintiff alleges that CNA was a victim of the fraud scheme perpetrated by Counsel Defendants. Hauber’s role, if any, in the supposed RICO scheme is unclear. Count II is a breach of contract claim brought against CNA and Hauber. Plaintiff alleges that CNA paid Counsel Defendants without securing Plaintiff’s approval or providing her with an opportunity to review or contest expenses, as supposedly required under her policy. Id. at 19. Count III is a legal malpractice claim brought against Wilson Elser and Melichar, alleging various issues with the representation provided during the Colorado disciplinary proceedings. Id. at 21. Count IV is a bad faith claim against CNA premised largely on the same allegations

underlying Count II, i.e., that CNA mishandled Plaintiff’s insurance benefits by hiring and then improperly disbursing payments to Counsel Defendants without Plaintiff’s approval and despite her protests as to their incompetence. Id. at 25. Count V is an unjust enrichment claim brought against Counsel Defendants as to the payments they received from CNA for allegedly subpar work. Id. at 26. Count VI is a fraud claim brought against Counsel Defendants for allegedly misrepresenting that they could competently represent Plaintiff. Id. at 28.

4 ANALYSIS I. Personal Jurisdiction Defendants Melichar and Dr. Reiffel seek dismissal of Plaintiff’s claims against them for lack of personal jurisdiction. Once challenged, the plaintiff bears the burden of establishing personal jurisdiction. N. Grain Mktg., LLC v. Greving, 743 F.3d 487, 491 (7th Cir. 2014). If a

court rules on a defendant’s motion to dismiss for lack of personal jurisdiction without holding an evidentiary hearing, the plaintiff “need only make out a prima facie case of personal jurisdiction.” Purdue Rsch. Found. v. Sanofi-Synthelabo, S.A., 338 F.3d 773, 782 (7th Cir. 2003). In making this determination, the Court reads the complaint liberally and resolves factual disputes in the plaintiff’s favor. Greving, 743 F.3d at 491.

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Bluebook (online)
Kazazian v. CNA Financial Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kazazian-v-cna-financial-corporation-ilnd-2025.