HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS

HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS: "2. I am a former employee of State Farm Fire and Casualty Co.
and State Farm Mutual Automobile Insurance Co. (collectively,
'State Farm' or 'the Company'). I was employed there from 1988
through mid-1996, and in fact separated during the pendency of
the Taylor litigation. Since August of 1994, I worked first in
the Automobile Company's so-called 'SAC' unit ('Suits Against the
Company' unit) and then in the Fire Company's SAC unit. Later
these units were renamed, 'Litigation Units.' My most recent job
title before separation from the Company was Claims Specialist.
My responsibilities included evaluating bad faith suits brought
against the Company by insureds, responding to discovery and
monitoring litigation. I did so in connection with the Taylor"

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