On May 6, 2000, plaintiff Nancy Keltner learned that her home, with panoramic views and located on 2.76 acres atop Tunnel Road in Santa Barbara, burned down in the Jesusita Fire, a wildfire in the hills of Santa Barbara that began on May 5, 2009, and destroyed 80 homes while damaging 15 others before being contained. Keltner previously paid $2 million for the home in June 2007 It was appraised at $800,000, while the land was appraised at $1.2 million. Thus, she claimed that her $1 million insurance policy was not sufficient and that her insurance agent, Michelle Tamburri, was negligent for failing to require her to get additional insurance. Keltner sued Tamburri and her employers, Tamburri & Associates Insurance Agency, Certain Underwriters at Lloyd’s of London and Certain Underwriters at Lloyd’s of London Syndicate 33. She alleged that Tamburri’s failure to mention that more insurance was needed constituted professional negligence. Keltner also alleged that Tamburri’s employers’ actions constituted a breach of contract. Certain Underwriters at Lloyd’s of London subsequently filed a cross-complaint against Keltner, Tamburri and Tamburri & Associates Insurance Agency. Keltner claimed that it would cost $3.5 million to rebuild her home, and that she was underinsured with insurance coverage for approximately $1 million. The plaintiff’s standard of care expert opined that Tamburri’s actions fell below the standard of care of an insurance agent and that Tamburri should have required Keltner to get more insurance coverage. Tamburri asserted that Keltner wanted only the minimum amount of insurance necessary to satisfy the bank, which was approximately $1 million. She claimed that a result, she obtained that amount of insurance for Keltner, per Keltner’s written request. Defense counsel asserted it is the responsibility of Keltner, the homeowner, to decide the amount of insurance she wanted on her home. Counsel noted that Keltner was sophisticated in insurance, with an acquired MBA. Counsel further noted that Keltner put in writing that the $1 million in insurance obtained was “fine” with her and that the bank was also fine with that amount. The defense’s construction experts showed that it would cost about $1 million to rebuild Keltner’s home, rather than the $3.5 million proffered by Keltner. In addition, defense counsel contended that the plaintiff’s standard of care expert was impeached on a variety of material issues involving his qualifications and had admitted to numerous “half-truths” involving his qualifications. According to defense counsel, one example of this was the plaintiff’s expert claiming that he obtained an MBA from the Wharton School of Business when, in fact, he did not, but, instead, attended a seminar at that location., Keltner sought recovery of $3.5 million in damages in order to rebuild the subject home. She also sought recovery of $1 million in damages for her emotional distress.