FAGG, Circuit Judge.
Jack Irons and his friend Eugene Berogan were involved in a car crash when Berogan, who was following Irons, struck Irons's van. The car Berogan was driving belonged to another friend of Irons, Richard Dirks. Irons claimed he suffered disabling headaches because of the collision. He obtained disability benefits through two insurance policies with the SMA Life Assurance Company (SMA), and received payments for medical expenses and the damage to...
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