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Natalie Kouyoumdjian

  Natalie Kouyoumdjian

NKouyoumdjian@romalaw.com
213-706-8000

Natalie Kouyoumdjian is a certified appellate specialist. Her clear and concise writing makes even the most complicated legal analysis easy to follow. Her ability to accurately frame the factual background in a way that compels the conclusion that the client's position is meritorious has led to many successful results. In addition to her appellate work, she regularly writes complex dispositive motions. She is an adjunct professor of law at the USC Gould School of Law where she teaches Legal Research, Writing and Advocacy.

 
 

Favorite Cases

In State Farm Insurance Co. v. Frake (2011) 197 Cal.App.4th 568, the Court of Appeal found that there was no duty to defend the insured for the deliberate act of striking his friend in the groin as a part of a "consensual game." While there was no dispute that the friend suffered severe injury as a direct result of the strike, the injury did not result from "some unexpected, independent and unforeseen happening" in the causal chain producing the harm. The injuries were the direct and immediate result of an intended event. The mere fact that the insured did not intend to injure his friend did not transform the insured's intentional conduct into an accident. The Court of Appeal reversed the trial court ruling and vacated the stipulated judgment, which was entered against the insured for $670,000.

In Kazi v. State Farm Fire and Casualty Company (2001), 24 Cal.4th 871, the California Supreme Court concluded that there was no potential for coverage under a comprehensive liability policy for injury to intangible property rights. The insured alleged there was an obligation to defend a claim for damages brought after the insured graded a strip of property which was subject to an easement. The trial court granted a motion for nonsuit; the Court of Appeal reversed. The California Supreme Court concluded that an easement represented only a non-possessory right to use another's property and was not tangible property. There was no duty to defend the underlying action since the damages sought arose from an intangible property right; the grading of the land did not make the loss tangible.

When State Farm stopped offering guaranteed replacement cost coverage in homeowner policies, it provided each policyholder with a notice of the change in coverage and sent, with the annual renewal certificate, a reminder that it was the insured's responsibility to purchase adequate coverage. Although a replacement cost estimate was provided with the renewal certificate, State Farm warned that the actual replacement cost could be significantly different. After an insured's home was destroyed in a wildfire, she asserted that State Farm was obligated to pay the entire cost to replace the home and that the notice sent by State Farm when it eliminated replacement cost coverage was invalid under Insurance Code section 678. Summary judgment was granted in favor of State Farm and upheld on appeal in Everett v. State Farm General Insurance Co., (2008) 162 Cal.App. 4th 649. The Court held there was no obligation to replace the home; no obligation to maintain policy limits equal to replacement cost; no obligation to annually adjust the policy limits to keep up with inflation; and no obligation of the agent to make certain that the coverage was sufficient to cover the full replacement cost. The result enabled resolution of a multitude of other actions arising out of wildfires in which similar claims were made.

After a substantial judgment was entered against a homeowner, his property was damaged by fire. The homeowner submitted a claim to State Farm under his homeowner's policy. Arson was suspected and the claim was denied because of the insured's failure to provide information as required by the policy. The property was purchased at a Sheriff's sale; the proceeds satisfied a portion of the mortgage and State Farm paid the remainder in accordance with the Lender's Loss Payable endorsement. The buyer of the property claimed the right to additional policy proceeds as a successor-in-interest, asserting that he had not been able to inspect the interior of the dwelling before it was purchased at the Sheriff's sale, and, had he been able to do so, he would not have paid the amount that he did. The Court of Appeal affirmed summary judgment, holding that "Although the buyer might have become the former owner's successor-in-interest with respect to the property, the buyer did not automatically become the former owner's successor-in-interest on the former owner's homeowner's insurance policy." (Washington Mutual Bank v. Jacoby (2009) 130 Cal.App.4th 639.)

Memberships

  • State Bar of California, Member, Appellate Courts Committee
  • Los Angeles County Bar Association Member, Appellate Judicial Evaluation Committee 2011-2012
  • American Bar Association
  • Association of Southern California Defense Counsel

Distinctions

  • Certified Specialist, Appellate Law, The State Bar of California Board of Legal Specialization
  • Adjunct Professor of Law, USC Law Center, 2005-Present
  • Listed, Super Lawyers Southern California Rising Stars, 2006-2008
  • Los Angeles Daily Journal, co-author with Kyle Kveton, "State Supreme Court Made the Right Decision in Jarrow"

Education

  • Southwestern University, School of Law, J.D., 1994
    • Member, 1992-1993 and Research Editor, 1993-1994, Southwestern University Law Review
    • Recipient, Mable Wilson Richards Scholarship
  • Judicial Extern to Judge Edward Rafeedie, U.S. District Court, Central District of California, 1993
  • University of Southern California, B.A., 1991

Admissions

  • California, 1994
  • U.S. District Court, Southern District, 2011
 


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