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    D-l-cN-14-0047A4 Venkataramani Mani, Plaintiff IN: County

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    johan guttenberg
    Venkataramani Mani filed a lawsuit against Sirius International Insurance Corporation and International Medical Group for breach of contract and violations of the Texas Insurance Code. Mani had purchased an international medical insurance plan from the defendants but they denied his claim for medical expenses incurred in the United States for acute cholecystitis and liver conditions. Mani is seeking damages, attorney's fees, and other relief allowed under Texas law. The case is being heard in Travis County District Court.

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    D-l-cN-14-0047A4 Venkataramani Mani, Plaintiff IN: County

    Uploaded by

    johan guttenberg
    2K views5 pages
    Venkataramani Mani filed a lawsuit against Sirius International Insurance Corporation and International Medical Group for breach of contract and violations of the Texas Insurance Code. Mani had purchased an international medical insurance plan from the defendants but they denied his claim for medical expenses incurred in the United States for acute cholecystitis and liver conditions. Mani is seeking damages, attorney's fees, and other relief allowed under Texas law. The case is being heard in Travis County District Court.

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    lawsuite 123

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    lawsuit2

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    Venkataramani Mani filed a lawsuit against Sirius International Insurance Corporation and International Medical Group for breach of contract and violations of the Texas Insurance Code. Mani had purchased an international medical insurance plan from the defendants but they denied his claim for medical expenses incurred in the United States for acute cholecystitis and liver conditions. Mani is seeking damages, attorney's fees, and other relief allowed under Texas law. The case is being heard in Travis County District Court.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    2K views5 pages

    D-l-cN-14-0047A4 Venkataramani Mani, Plaintiff IN: County

    Uploaded by

    johan guttenberg
    Venkataramani Mani filed a lawsuit against Sirius International Insurance Corporation and International Medical Group for breach of contract and violations of the Texas Insurance Code. Mani had purchased an international medical insurance plan from the defendants but they denied his claim for medical expenses incurred in the United States for acute cholecystitis and liver conditions. Mani is seeking damages, attorney's fees, and other relief allowed under Texas law. The case is being heard in Travis County District Court.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    of 5
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    The plaintiff developed acute cholecystitis and liver conditions while visiting family in the US and is suing his insurance providers for denying coverage of his medical bills.

    The plaintiff developed acute cholecystitis and liver conditions.

    The cholecystitis was treated with a laparoscopic cholecystectomy and the plaintiff received treatment for the liver conditions.

    Case 1:14-cv-01103-SS Document 1-3 Filed 12/12/14 Page 1 of 5 1ilt1

    '':, PM ,

    riOuez-.Menfoza ,

    . , T¡avis County .

    No. D-l-cN-14-0047A4 ' '

    VENKATARAMANI MANI, IN THE DISTRICT COURT OF


    Plaintiff

    TRAVtrS COUNTY, TEXAS


    SIRIUS INTERNATIONAL INSURAhICE
    CORPORATION and INTERNATIONAL
    MEDICAL GROUP,'INC.,
    Defendants ?91Sr - TDICIALDI'TRICT

    TO THE HONORABTE COIJRT: : ': . r'

    files'this öriginal'petition complaining


    '' :
    of '

    Sirius :)lanA,tnæøation"l Mrdiral Group,Inc.


    '..''..
    . _ t .. .'.

    ('¿International')andwouldshow: ',.' '. ' .', '


    .:...... . .' .t-
    '' . :
    '

    Control Plan, Level2.

    denial of an insurarice claim.,

    ITI, PittÍes

    Plaintiffis an individual residing if Travis County,,fsxas.


    Case 1:14-cv-01103-SS Document 1-3 Filed 12/12/14 Page 2 of 5

    Defendant, siti.rs International Insrrance Coqpóration; is a foreigu,urpt r" linos insurance


    '

    company doing business in Texas that does not maintain a registered agent in Texas, and may be
    .:. . ,

    served with cit¿tion by and through the Commissioner of lnsuance, JuliaRathgeber, P,O. Box

    International, Insurance Corporation,'./o Edwæds Mldman Palmer, LLP, 750 Lexington


    :

    Averrue, 8ú Floor, New York, NY 10022-9833.

    Defendant, Internationat Medical Gro


    :

    , the'State of Texas that does not mantain


    '..t......
    a:regi

    citation by and through the Texas Secreta¡y of.


    ' '.. :. . -:,
    ......:....
    International Medical Group, Inc., 2960, North

    4715.,..:),

    fV, Venuê

    ' Venue is proper in Travis

    ''lt.1
    omissions giving rise to PlaintifPs

    :' .
    :

    CodeAnn. $ 15.002(a)(1). :

    VL X'acts of the Case


    : : lvh. Mani is a citiZen of India. ,Hr o
    '.'
    :

    medical insurance from Defendants for thè perio


    Case 1:14-cv-01103-SS Document 1-3 Filed 12/12/14 Page 3 of 5

    to Austin, Texàs to visit his son's family: After he had been in the IJrrited States for

    approximately a month, Mr. Mani,developed, for the fú$ qtné in his':!ife, acute cholecystitis and
    ,

    liver
    .:....
    Mr. Mani was forced to seek medical fieatntent for these'conditions that first started in
    ''
    , the United St¿tes:at great expense.'The liver
    . ..t..

    the Cholecy. stltis .was'freatéd wittr. a lapæoscopic


    : : . '' . : .. - . .: .

    fromlthese conditions.
    -:
    :. ..: ... . I .'

    M¡. Mani's medical bills were'submitte


    .':
    investi-gatión, Greg'Weâver, RN, of Akeso Care

    ',Mani's treatment,was, a il'non-covered servic

    individuat ïyith MCMC, unote:a letter.ctai

    Defendants have not paid any of Mr. Mani's o

    rBreach ¡if Côntract '.,

    Defendants? actions amount to ¿breach of contract between.Þlaintiff and Defendants.l

    plaintiffapplied for and was accepted for rnsurance coÌerage by Ddendants. He paid the

    ;.
    requüed premiums, entering into a binding co
    '..r.'. :" i . l . .'
    .:.
    breached the conüact by denying Plaintiffs clai
    :

    ''
    reçöver his actuat damages, court costs and reaso
    '

    Texas Civil Practice.& Rernedies Code, Section'318,001;et seq.


    ': :'
    :

    . :
    Case 1:14-cv-01103-SS Document 1-3 Filed 12/12/14 Page 4 of 5

    .,i,......
    Texas Insurance Code: (1) $5a1.060(a)(1) misrepre¡enting'to a claimant a material fact or policy
    ''
    provision relating to coverage at issue; (2) $541.060(a)(2)(A) failing to auempt in good faith to

    effectuate a prompt, fair, and equitable settletnenf of a claim with resp ct to which the insurerls

    policyholder a reasonable'explanation'of the,basis in the policy, in:relation to the' facts or

    applicable law, forthe insurer's deriial'of a'c


    t '
    ' '' . . . .

    and (4) $5a1.060(a)(7) refrrsing to pay,a clai


    ':
    with respect to'the claim; As,a result, Pl
    '''''':
    jurisdictional limits of this cor¡¡t.

    DL' Third Câuse of Action¡


    ' Deféndant?s'actions also arfiount to a violation,of Texas Insurancel Côde, Sèetións: .,

    .l : .

    542.051-0t61 . As such, Plaintiff is :entitled to l8o/o per :


    *num i¡ a¿Atio¡ toi the aurotmt 'of his'

    claim, plus auornéyst fees.

    . À. .. .. ...
    .-:. .:i :

    . Plaintiffhas requested ttrat this case'be y a jury'as allowed'by, Tex. R, Civ, P

    216. T\e appropriate jury fee has been paíd; ' . r l - l, t


    ..ì :.:
    .

    '

    '
    Case 1:14-cv-01103-SS Document 1-3 Filed 12/12/14 Page 5 of 5

    'XI.r Praiêr

    which Plaintiff may show himself justly entitled.,

    Texas 78731
    -100-6
    ,stzqie-^égs ræ<

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