FORMER STATE FARM EMPLOYEE TESTIFIES THAT STATE FARM AGENTS AND EMPLOYEES REGULARLY FORGE CUSTOMER SIGNATURES: "D. That instead of complying with requests for discovery by various plaintiffs, a carefully created 'packet' from which many documents were removed was prepared. One of the items removed was the index. Their tactic was to give plaintiffs something containing no damaging information but which was voluminous enough to distract their attorneys.
E. Prior to Ms. Zuniga’s deposition, she was specifically instructed by her supervisor, Vanessa Gudeij, that under no circumstances was she to 'give up' the name of David Tannenbaum to plaintiff’s counsel. Mr. Tannenbaum had told her that identical, screened packets of discovery documents referred to above were to be produced in all earthquake cases in response to discovery requests, regardless of the specifics of the particular facts of the case."
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