HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS: "11. Additionally, after agreeing to a Stipulation and Order Re:
Confidentiality which was provided to me by plaintiff's counsel,
I reviewed the documents which have been bates stamped SFCM
0001-0094. According to the Stipulation and Protective Order
these are all portions of the claims manual and/or claims
handling procedures documents which are responsive to the Request
for Production of Documents submitted by the plaintiff, Request
No. 1, Item No. 2. State Farm did not identify any portion
that was not produced (as required by the stipulation).
12. Based on my own personal knowledge, State Farm's response to
the Request for Production is false and materially incomplete."
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